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LOS VAQUEROS 



A Water Quality and Resource Management Project 

Sponsored by 
Contra Costa Water District 

Attachments to the Final 

Stage 2 Environmental Impact Report/ 

Environmental Impact Statement 

for the Los Vaqueros Project 

SCH #91063072 

Volume II 



Lead Agencies: 

Contra Costa Water District 
Concord, California 

U.S. Department of the Interior 

Bureau of Reclamation, Mid-Pacific Region 

Sacramento, California 



Technical Assistance Provided by: 

Jones & Stokes Associates, Inc. 

Montgomery Watson Americas 

Woodward-Clyde Consultants 

Sonoma State University 



September 27, 1993 
LOS VAQUERC^ 



Table of Contents 



Attachment 1. Draft Amended Water Sen/ice Contract No. I75r-3401 1-1 

Attachment 2. Effects of Revised Project Operations on DeJta Diversions 2-1 

Attachment 3. Additional Guttural Resources Information 3-1 

Attachment 4. Fish and Wildlife Ckx)rdination Act Compliance 4-1 

Attachment 5. Letters of Comment Received on the Draft EIR/EIS and 

Responses to Those Comments 5-1 



Attachment 1. Draft Amended Water Service Contract No. 175r-3401 



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R.O. Draft 6/26-1992 

Amendatory Contract No. 
I75r-3401 

UNITED STATES 
DEPARTMENT OF THE INTERIOR 
BUREAU OF RECLAMATION 
Central Valley Project, California 

AMENDATORY CONTRACT BETWEEN THE UNITED STATES 

AND CONTRA COSTA WATER DISTRICT 

PROVIDING FOR WATER SERVICES AND FOR FACILITIES REPAYMENT 



Table of Contents 

Article No. Title Page No. 

Preamble 1 

Explanatory Recitals 1- 2 

1 Definitions 3- 5 

2 Term of Contract-Right to Use of Water 5- 6 

3 Water to be Made Available and Delivered to 

the District 6- 7 

4 Time for Delivery of Water 8- 9 

5 Points of Delivery and/or Diversion-Measurement-- 

Responsibility for Distribution of Water 9-13 

6 Rate and Method of Payment for Water 13-15 

7 Repayment of Project Works 16-17 

8 Transfers or Exchanges of Water 17-18 

9 Project Use Power 18-19 

10 Adjustments 19 

11 Temporary Reductions-Return Flows 20 

12 Water Shortage and Apportionment 21-23 

13 Existing or Acquired Water or Water Rights 23-24 

14 Quality of Water 24 

15 Water and Air Pollution Control 24 

16 Operation and Maintenance of Project Works 25-28 
: 17 Conveyance of Non-Project Water 28-29 

18 District to Pay Certain Miscellaneous Costs 

Relating to Project Works 29 

19 Emergency Reserve Fund 29-30 

20 Transfer of Title to Project Works 31 

21 Performance of Work with Contributed Funds 31-32 

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R.O. Draft 6/26-1992 



22 General Obligation-Benefits Conditioned ^^ 

Upon Payment ^2 

23 Compliance with Reclamation Laws ^^ 

24 Books, Records and Reports r t:- j^ -^^ 
^ Contingent on Appropriation or Allotment of Funds 33 

26 Rules, Regulauons and DeterrainaUons ^^ 

27 Officials not to Benefit ^4 

28 Notices . A • 

29 Assignment Umited-Succcssors and Assigns ^^ 

Obligated 24.35 

30 Equal Opportunity - , 

31 Charges for Delinquent Payments 

32 Compliance with Civil Rights Laws ^^ 

and Regulations y. 

33 Privacy Act Compliance 

34 Confirmation of Contract . 

35 Water Conservation 

36 Changes in District's Organization ^^ 
Signature Page 



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R.O. Draft 6/26-1992 

1 Amendatory Contract No. 

2 I75r-3401 

3 UNITED STATES 

4 DEPARTMENT OF THE INTERIOR 

5 BUREAU OF RECLAMATION 

6 Central Valley Project, California 

1 AMENDATORY CONTRACT BETWEEN THE UNITED STATES 

2 AND CONTRA COSTA WATER DISTRICT 

3 PROVIDING FOR WATER SERVICES AND FOR FACILITIES REPAYMENT 

4 TPnS AMENDATORY CONTRACT is made this day of , 



5 1992, in pursuance generally of the Act of June 17, 1902 (32 Stat. 388), and acts 

6 amendatory thereof or supplementary thereto, all collectively hereinafter referred to as 

7 the Federal reclamation laws, between THE UNITED STATES OF AMERICA, 

8 hereinafter referred to as the United States, and CONTRA COSTA WATER 

9 DISTRICT, hereinafter referred to as the District, a pubUc agency of the State of 

10 California, duly organized, existing, and acting pursuant to the laws thereof, with its 

11 principal place of business in Contra Costa County, California, 

12 WTTNESSETH, That: 

13 EXPLANATORY RECTTALS ' 

14 WHEREAS, the United States has constructed and is operating the 

15 Central Valley Project (CVP) for the purpose, among others, of furnishing water for 

16 irrigation, municipal, industrial, domestic, and other beneficial uses. The District and the 

17 United States entered into a contract, dated September 18, 1951, designated by symbol 

18 and number i75r-3401, amended November 9, 1970, providing water service from the 

19 CVP, and for construction and repayment of certain facilities. This contract is 

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R.O. Draft 6/26-1992 

1 hereinafter referred to as "the existing contract" The existing contract has been 

2 amended and supplemented through an amendment, dated April 26, 1973, and other 

3 written agreements; and 

4 WHEREAS, the District is currently developing a Los Vaqueros Project 

5 That project is intended to exclusively serve the District to assist it in attaining its goals 

6 of providing high quality water to District customers, while also providing reliability to 

7 the District's existing contract water supply during emergencies, droughts or other water 

8 shortages; and 

9 WHEREAS, in order to proceed with the Los Vaqueros Project, it is 

10 necessary for the District and the United States to agree on how that Project will be 

11 utilized in conjunction with CVP water and CVP facilities. In this regard, the existing 

12 contract must be further amended; and 

13 WHEREAS, sections 105 and 106 of PubUc Law No. 99-546 (100 Stat 

14 3050) and sections 203, 205 and 208 of the Reclamation Reform Act of October 12, 1982 

15 (96 Stat. 1263; 43 U.S.C. §§ 390cc, 390ee, 390hh) require annual adjustment in the rates 

16 to be paid by the District for CVP water made available pursuant to this contract; 

17 NOW, THEREFORE, in consideration of the mutual covenants herein 

18 contained, it is agreed that the existing contract, as amended, is further amended so that 

19 the contract between the United States and the District now reads, in its entirety, as 

20 follows: 

21 // 



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R.O. Draft 6/26-1992 

1 DEFINITIONS 

2 1. When used herein, unless otherwise distinctly expressed or manifestly 

3 incompatible with the intent hereof, the terms: 

4 (a) "Secretary" or "Contracting Officer" shall mean the Secretary of the 

5 Interior or his duly authorized representative; 

6 (b) "CVP" shall mean the Central Valley Project, California, of the 

7 Bureau of Reclamation; 

8 (c) Unless otherwise specifically provided, "Year" shall mean that period 

9 of time from and including March 1 of each calendar year through the last day of 

10 February of the following calendar year; 

11 (d) "Contra Costa Canal System" shall mean the Contra Costa Canal, 

12 including the intake channel from Rock Slough, Clayton and Ygnacio Relift 

13 Canals and pumping plants, the Martinez Reservoir and Pumping Plants 1, 2, 3, 

14 and 4; 

15 (e) "Contra Loma Dam and Reservoir" shall mean the dam, pumping 

16 plant, and reservoir constructed as an addition to the Contra Costa Canal System; 

17 (f) "New Facilities" shall mean the Short Cut P^>eline located between 

18 Contra Costa Canal Milepost 25.70 and Milepost 47.77 and the Pump Units in 

19 Pumping Plant 1, 2, 3 and 4 of the Contra Costa Canal System; 

20 (1) "Short Cut Pipeline" shall mean the Contra Costa Canal 

21 intake, pipeline, pipeline appurtenances, Martinez Reservoir inlet; and 



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R.O. Draft 6/26-1992 

1 (2) "Pump Units" shall mean the pump, motor, motor controls, 

2 wiring, structural supports and discharge control apparatus for pumping 100 

3 cubic feet per second ("c£s") of water; 

4 (g) "Lateral Distribution System" shall mean that water conveyance 

5 system constructed by the United States which consists of pipelines extending 

6 service to District water users from the Contra Costa Canal at Milepost 53, 62, 

7 7.1, 73, 9.1, 14.0, 25.6, 36.6 and Y-2-6; 

8 (h) "Project Works" shall mean all those facilities defined in subsections 

9 (d), (e), (f) and (g) of this article; 

10 (i) The terms "water for irrigation use" or "irrigation water" shall mean 

11 water made available from the CVP which is used primarily in the production of 

12 agricultural crops or livestock, including domestic use incidental thereto, and the 

13 watering of livestock; 

14 (i) The terms "water for M&I use" or "M&I water" shall mean water 

15 made available from the CVP o±er than irrigation water. M&I water shall 

16 include water used for purposes incidental to domestic uses such as the watering 

17 of landscaping or pasmre for animals (e.g^ horses) which are kept for personal 

18 enjoyment and water delivered to landholdings operated in units of less than two 

19 acres unless the District establishes to the satisfaction of the Contracting Officer 

20 that the use of the water delivered to any such landholding is a use described in 

21 subdivision (i) of this article; 



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R.O. Drafc 6/26-1992 

1 (k) "O&M" shall mean normal and reasonable care, control, operation, 

2 repair, replacement, and maintenance; 

3 (I) "Los Vaqueros" shall mean the Los Vaqueros Project consisting of a 

4 storage reservoir and associated facilities to be constructed by the District to store 

5 and convey Los Vaqueros water rights water and CVP water as well as additional 

6 water that may be acquired by the District; 

7 (m) "Los Vaqueros water rights water" shall mean that water 

8 appropriated pursuant to State Water Rights Application 20245; and 

9 (n) "CVP water" shall mean that water appropriated by the United 

10 States for the operation of the CVP in addition to and not including the Los 

11 Vaqueros water rights water; and 

12 (o) "District Service Area" shall mean the area to which the District 

13 provides continuing service, 

14 TERM OF CONTRACT-RIGHT TO USE OF WATER 

15 2. (a) This amendatory contract shall be effective on the date first 

16 hereinabove written and shall remain in effect through December 31, 2010; Provided. 

17 that under terms and conditions agreeable to the parties hereto, renewals of this 

18 amendatory contract may be made for successive periods not to exceed forty (40) 

19 calendar years each. The terms and conditions of each renewal shall be agreed upon 

20 within a reasonable time prior to the expiration of the then existing contract; Provided 

21 further , that upon written request of the District to the Secretary not later than one (1) 



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R.O. Draft 6/26-1992 

1 calendar year prior to the expiration of this contract, whenever, account being taken of 

2 the amount then credited to the costs of construction of the CVP allocated to irrigation, 

3 and the remaining amount of such costs properly assignable for ultimate return by the 

4 District as established by the Secretary of the Interior pursuant to Subsection 1 (3) of 

5 Public Law 643 (70 Stat 483) probably can be repaid to the United States within the 

6 term of a contract under subsection 9 (d) of the 1939 Reclamation Project Act (53 Stat. 

7 1187), the portions of this contract pertaining to the furnishing of irrigation water may be 

8 converted to a contract under said subsection 9 (d) upon terms and conditions agreeable 

9 to the United States and the District; and Provided Further, that the charges set forth in 

10 the renewal of this contract for M&I water pursuant to Pubhc Law 88-44 (77 Stat 68) 

11 shall be set in accordance with the applicable CVP water ratesetting policy in effect at 

12 the time of renewal. 

13 (b) The right to the beneficial use of water to which the District is entitled 

14 pursuant to this contract and any renewal thereof shall not be disturbed so long as the 

15 District fulfills all of its obligations under this contract and such renewal. 

16 WATER TO BE MADE AVAILABLE AND DELIVERED TO THE DISTRICT 

17 3. (a) Subject to the provisions set forth in subdivisions (d) and (e) of this 

18 Article, Articles 1 1 and 12 hereto, and consistent with applicable state water rights 

19 permits and licenses, the District is entitled to, and the Contracting Officer shall make 

20 available to the District, up to 195,000 acre-feet of CVP water during any Year. The 

21 quantity of CVP water to be delivered to the District in any Year shall be scheduled and 



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R.O. Draft 6/26-1992 

1 paid for pursuant to the provisions of Articles 4 and 6 hereof, which shall not exceed the 

2 quantity of water the District intends to put to reasonable beneficial use within the 

3 District Service Area during that Year. During any Year in which the District does not 

4 schedule the full 195,000 acre-feet of CVP water to which it is entitled, the United States 

5 shall put the unused portion of such CVP water to reasonable beneficial use for CVP 

6 purposes, consistent with applicable state water rights permits and licenses. 

7 (b) In no event shall the total quantity of CVP water and Los Vaqueros water 

8 rights water, distributed within the District Service Area, in any Year for use by its 

9 customers, exceed 195,000 acre-feet 

10 (c) The District shall operate the Los Vaqueros Project in accordance with 

11 applicable state water rights permits and licenses. 

12 (d) During the period commencing January 1, 1993 and ending February 28, 

13 1993, the District is entitled to .and the Contracting Officer shall make available to the 

14 District a quantity of CVP water not to exceed 32,500 acre-feet. 

15 (e) During the period commencing March 1, 2010 and ending December 31, 

16 2010, the District is entitled to and the Contracting Officer shall make available to the 

17 District a quantity of CVP water not to exceed 195,000 acre-feet less the quantity 

18 actually delivered to the District pursuant to subdivision (d) above. 

19 // 

20 // 

21 // 



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R.O. Draft 6/26-L992 

1 TIME FOR DELIVERY OF WATER 

2 4. (a) The District shall submit to the Contracting Officer by November 1, 

3 1992 or on the effective date of this contract, whichever is later, a written schedule, 

4 satisfactory to the Contracting Officer showing the times and quantities of CVP water to 

5 be delivered by the United States to the District during the period January 1, 1993 

6 through February 28, 1993. In addition, the District shall furnish forecasts of its 

7 conveyance of non-project water during the months of January and February of 1993. 

8 (b) The District shall submit to the Contracting Officer, by January 1 of 

9 each calendar year and at such other times as necessary, a written schedule, satisfactory 

10 to the Contracting Officer, showing the times, quantities and points of delivery of CVP 

11 water to be delivered by the United States to the District during the upcoming Year. In 

12 addition, the District shall furnish forecasts of its operation of Lx)s Vaqueros Project 

13 including the times and quantities of CVP water and Los Vaqueros water rights water to 

14 be diverted to and released from storage during the upcoming Year. The District shall 

15 also provide its forecasts of the conveyance and use of non-project water during the 

16 upcoming Year. 

17 (c) By February 15 of each calendar year, the United States shall 

18 furnish the District with its forecast of CVP operations during the upcoming 12 months. 

19 Subsequent forecasts will be furnished to the District each month through May of each 

20 calendar year as soon as such forecasts are completed. 



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R.O. Draft 6/26-L992 

1 (d) The schedules and forecasts referred to above shall be prepared and 

2 exchanged so as to provide the parties with sufficient information within a reasonable 

3 time to assist both in performing their respective obligations under this contract, 

4 (e) Subject to the conditions set forth in Article 3(a) hereto, the United 

5 States shall deliver CVP water to the District in accordance with the initial schedules 

6 submitted by the District pursuant to subdivisions (a) and (b) above, or any revision(s) 

7 thereto submitted within a reasonable time prior to the date(s) on which the requested 

8 change(s) is/are to be implemented. 

9 pon^rrs of delivery and /or diversiqn-measurement- 

10 RESPONSIBILITY FOR DISTRIBUTION OF WATER 

11 5. (a) All CVP water made available to the District pursuant to this 

12 contract shall be delivered in Rock Slough at the intake of Pumping Plant 1 of the 

13 Contra Costa Canal System or in the Sacramento-San Joaquin Delta. Such deliveries in 

14 the Sacramento-San Joaquin Delta may be made at the intake to the Tracy Pumping 

15 Plant of the CVP at Old River, the intake of the State Water Project to Clifton Court at 

16 Old River and/or the intake to Los Vaqueros at Old River. Los Vaqueros water rights 

17 water shall be delivered and/or diverted in the Sacramento-San Joaquin Delta. Said 

18 point or points of delivery and/or diversion of CVP water and Los Vaqueros water rights 

19 water shall be subject to change by written agreements of the parties hereto; Provided . 

20 that such change(s) is/are consistent with the applicable state water right perniit(s) or 

21 license(s) as they may be amended or modified. The United States shall not be 



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R.O. Drafc 6/26-1992 

1 obligated to construct additional facilities for the delivery and/or diversion of water 

2 under this contract 

3 (b) The United States shall not be responsible for the control, carriage, 

4 handling, use, disposal, or distribution of water diverted by the District pursuant to this 

5 contract beyond the delivery points specified in subdivision (a) of this Article, and the 

6 District shall hold the United States harmless on account of damage or claim of damage 

7 of any nature whatsoever for which there is legal responsibility, including property 

8 damage, personal injury or death arising out of or connected with the control, carriage, 

9 handling, use, disposal, or distribution of such water beyond such delivery points;" 

10 Provided, that this section is not intended to allocate the relative responsibilities of 

11 either the United States or the District under the Endangered Species Act, 16 U.S.C 

12 1531. 

13 // 

14 // 

15 // 

16 // 

17 // 

18 // 

19 // 

20 // 



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R.O. Draft 6/26-1992 
(c) Water diverted by the District pursuant to this contract shall be 
measured and recorded by the District for each of the points set forth below through 
measuring and recording devices, acceptable to the Contracting Officer; Provided, the 
parties hereto, may agree in writing that such points and/or method of water 
measurement may be changed or added to. The District shall O&M each of the 
measuring and recording devices at no cost to the United States. Except for Rock 
Slough at the intake to Pumping Plant 1, the District shall install all measuring and 
recording devices. 

(1) At the intake to Pumping Plant 1 of the Contra Costa Canal 
System; 

(2) At the intake to Los Vaqueros in Old River; 

(3) At the intake to the Los Vaqueros storage reservoir; 

(4) At the point at which the Los Vaqueros water rights water 
and CVP water diverted from other than Rock Slough are introduced into the 
Contra Costa Canal System from Los Vaqueros; and 

(5) At the points of distribution to the District's irrigation water 
users. 

// 

// 

// H 

// 



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R.O. Draft 6/26-1992 

1 (d) The District shall measure or compute and record daily, or at such 

2 other intervals as may be agreed upon in writing by the parties, and provide to the 

3 United States on or before the 7th day of each month following the month in which the 

4 measurement or computation was made the rates and quantities associated with the 

5 following: 

5 (1) Diversion of CVP water at Rock Slough; 

7 (2) Diversion of CVP water from Old River for direct use; 

8 (3) Diversion of Los Vaqueros water rights water to storage in 

9 Los Vaqueros storage reservoir; 

10 (4) Diversion of CVP water to storage in Los Vaqueros storage 

11 reservoir, 

12 (5) Diversion to storage in Contra Loma Dam and Reservoir; 

13 (6) Withdrawal of CVP water from Los Vaqueros storage 

14 reservoir; . 

15 (7) Withdrawal of Los Vaqueros water rights water from Los 

16 Vaqueros storage reservoir, 

17 (8) Withdrawal of water from Contra Loma Dam and Reservoir 

18 for delivery to the East Bay Regional Park District pursuant to Contract No. 14- 

19 06-200-6023A, dated September 18, 1972, as amended on November 29, 1977; 

20 (9) Withdrawal of water from Contra Loma Dam and Reservoir 

21 for purposes other than that specified in subdivision (d)(8) above; 



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R.O. Drafc 6/26-1992 

(10) Total irrigation water distributed; and 

(11) Total M&I water distributed. 

(e) The District shall examine, test, and service all measuring and 
recording devices required by this contract to assure their accuracy. Upon the written 
request of either party or at least once a calendar year, the District and the Contracting 
Officer shall investigate the accuracy of all measuring and recording devices required by 
this contract and the District shall promptly correct any errors in measurement or 
recording disclosed by such investigation. If such devices are found to be defective or 
inaccurate, they shall be adjusted or repaired, or both, or replaced without expense to 
the United States. In the event the District neglects or fails to make such repairs or 
replacements within a reasonable time as may be necessary to satisfy the operating 
requirements of the Contracting Officer, the Contracting Officer shall determine the 
appropriate measurement(s) to be used to implement this contract pending the District's 
completion of the necessary repair(s) or replacement(s). 

RATE AND METHOD OF PAYMENT FOR WATER 
6. (a) The CVP water and the Los Vaqueros water rights water shall be 
considered M&I water except for the quantities of such water reported pursuant to 
subdivision (d)(10) of Article 5 above. The rates of payment to be made by the District 
for Los Vaqueros water rights water and CVP water made available to it pursuant to this 
contract shall be the applicable rates determined annually in accordance with applicable 



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R.O. Draft 6/26-1992 

1 federal law. associated regulations, and the then current ratesetting policies for the CVP. 

2 The rates applicable during the initial Year of this contract are set forth in Exhibit "A". 

3 (b) Prior to October 15 of each calendar year, the Contracting Officer 

4 shall make available to the District an estimate of the rates of payment for the following 

5 Year and the computations and cost allocations upon which those rates are based. The 

6 District shall be allowed not less than two months to review and comment on such 

7 computations and cost allocations. By January 31 of each calendar year, the Contracting 

8 Officer shall provide the District with the final rates to be in effect for the upcoming 

9 Year. The final rates should be provided to the District in the format set forth in 

10 Exhibit "A"; Provided , that such format may be revised from time to time by mutual 

11 agreement of the parties hereto. 

12 (c) The District shall pay the United States each Year, in monthly 

13 payments as provided herein, for the quantities of Lx)s Vaqueros water rights water and 

14 CVP water for which the District is required to pay during each such Year, all at the 

15 rate(s) established pursuant to subdivision (a) of this article. At the time the District 

16 submits the initial schedule and forecast for each Year to the Contracting Officer 

17 pursuant to Article 4, the District shall pay the amount payable for all water scheduled 

18 and forecasted to be delivered and/or diverted pursuant to this contract dining the first 

19 two calendar months of that Year. Before the end of the first month or part thereof of 

20 that Year, and before the end of each month thereafter, the District shall pay for all the 

21 water to be delivered and/or diverted in accordance with its latest schedule and forecast 



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1 during the second calendar month immediately following. Adjustments between the 

2 payments for the scheduled and forecasted amounts of water and the appropriate 

3 payments for quantities of water actually delivered and/or diverted each month shall be 

4 made by the last day of the following month; Provided , that any revised schedule and 

5 forecast submitted by the District pursuant to Article 4 which increases the amount of 

6 water to be delivered and/or diverted shall be accompanied with appropriate payment to 

7 assure that water is not delivered and/or diverted in advance of payment In any 

8 calendar month in which the quantity of water delivered and/or diverted to the District 

9 pursuant to this contract equals the quantity of water scheduled and paid for by the 

10 District, no additional water shall be delivered and/or diverted to the District imless and 

11 until payment is made for such additional water. By February 1 of each calendar year, 

12 the District shall make any additional payment it is obligated to make for water made 

13 available to the District that Year pursuant to Article 3. 

14 (d) In the event the District in any Year is unable, fails, or refuses to 

15 divert of the quantities of CVP water scheduled under Article 4, and made available for 

16 delivery and for which payment is required pursuant to this contract, said inability, 

17 failure, or refusal shall not relieve the District of the obligation to pay for said water and 

18 the District agrees to make payment therefor in the same manner as if said water had 

19 been delivered to and diverted by the District in accordance with this contract. 

20 // i: 

21 // 



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R.O. Draft 6/26-1992 

1 REPAYMENT OF PROJ F.rT WORKS 

2 7. (a) The District shall adjust payment to the United Sutes by 

3 December 31. 1992, so that the remaining capitalized costs of the Contra Costa Canal 

4 System on December 31. 1992 shall be $2^81.53534. The District shall fully repay this 

5 amount, including interest at 25 percent per annum, by making 18 annual payments of 

6 $175,469.05. beginning January 1. 1993. and ending January 1. 2010. 

7 (b) The District shall adjust payments to the United States by 

8 December 31. 1992, so that the remaining capitalized costs of the New Facilities on 

9 December 31. 1992 shall be $3,787,414.66. The District shall fuUy repay this amount, 

10 including interest at 3342 percent per annum, by making 18 annual payments of 

11 $274,236.73, beginning January 1, 1993, and ending January 1, 2010. 

12 (c) The District shall adjust payments to the United States by 

13 December 31, 1992, so that the remaining capitalized costs of the Contra Loma Dam 

14 and Reservoir on December 31, 1992 shaU be $4393,55833. The District shall fully 

15 repay the amount, including interest at 3.137 percent per annum, by making 18 annual 

16 payments of $313,332.19. beginning January 1, 1993. and ending January 1, 2010. 

17 (d) The District may. instead of making the payments provided for in 

18 subdivisions (a), (b) and (c) above, at any time, make full payment of the sum then due 

19 and owing on any or all of the facilities described in those subdivisions; Provided , that 

20 the District agrees that such accelerated repayment shall not exempt the District from 

21 compliance with the otherwise applicable ownership and full cost pricing provisions of 



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R.O. Drafc 6/26-1992 

1 Federal reclamation laws. Outstanding balances to be repaid, including interest at the 

2 applicable interest rate, are shown as of December 31 of each calendar year through 

3 2010 on Exhibit "B". If payment is made at any other time in the year, the remaining 

4 payment balance as of such date will be determined by the Contracting Officer and 

5 provided to the District Upon full repayment, the District shall have no further 

6 repayment obligations associated with the capitalized costs specified in subdivisions (a), 

7 (b), and (c) above. 

8 (e) The remaining capitalized costs of the lateral distribution system, 

9 including interest at 2.5 percent per annum on the portion of such costs allocated to the 

10 delivery of M&I water, are $248,774.97 as of December 31, 1992. The District shall fully 

11 repay these costs (including additional interest at 2.5 percent per annum on the unpaid 

12 costs of the system allocated to the delivery of M&I water, for the period beginning 

13 January 1, 1993 through the actual date of full repayment) within one year of the 

14 execution of this contract 

15 TRANSFERS OR EXCHANGES OF WATER 

16 8. The District may sell, transfer or exchange the right to receive the CVP 

17 water provided for in this contract for beneficial uses within the State of California if, as 

18 determined by the Contracting Officer, such sale, transfer or exchange would be 

19 consistent with applicable federal and state laws and regulations then in effect and would 

20 not cause adverse effects on authorized CVP purposes or operation. No sale, transfer or 



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R.O. Draft 6/26-1992 

1 exchange of the right to receive water under this contract may take place without the 

2 prior written approval of the Contracting Officer. 

3 PROJECT USF POWER 

4 9. (a) During each Year, the United States shall furnish to the District the 

5 quantity of CVP project use power, not to exceed 164.8 kWh of energy for each acre-foot 

6 of CVP or Los Vaqueros water rights water, required to operate facilities needed to 

7 pump through the Contra Costa Canal System and Contra Loma Dam and Reservoir the 

8 full quantity of CVP water scheduled and the Lxis Vaqueros water rights water 

9 forecasted for delivery and diversion to and by the District for use within the District 

10 during that Year. Such quantity of CVP project use power may be utilized at one or 

11 more of the following locations: the Contra Costa Canal System; the intake of Los 

12 Vaqueros in Old River, Contra Loma Dam and Reservoir, and such other points of 

13 diversion set forth in Article 5(a) as may be mutually agreed upon. Project use power 

14 can only be used to convey CVP or Los Vaqueros water rights water and shall be 

15 available to pump no more than 195,000 acre-feet annually. 

16 (b) The United States may, at any time, request in writing that the 

17 District take delivery of some or all of the CVP water made available to the District 

18 pursuant to this contract at the point of diversion for Los Vaqueros water rights water in 

19 lieu of taking delivery of such water at the intake to Pumping Plant 1 of the Contra 

20 Costa Canal System at Rock Slough. If the District agrees in writing to such a request, 

21 the United States shall furnish to the District during the term of the agreement, the 



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R.O. Draft 6/26-L992 

1 quantity of CVP project use power required to pump said CVP water and Los Vaqueros 

2 water rights water from the intake to Los Vaqueros to the Los Vaqueros transfer 

3 reservoir, not to exceed 316 kWh of energy per acre-foot; Provided , that such a written 

4 agreement by the parties for the delivery to and diversion at the intake to Los Vaqueros 

5 of the full supply of CVP water made available under this contract during the term of 

6 such agreement shall not be implemented absent a modification acceptable to the 

7 Contracting Officer of applicable Sacramento-San Joaquin Delta water quality standards 

8 during the entire term of such agreement 

9 (c) The Distrirt shall pay the United States for the quantity of CVP 

10 project use power as set forth in subdivisions (a) and (b) above as a component of the 

11 water rates described in Article 6(a) of this contract. 

12 ADJUSTMENTS 

13 10. The amount of any overpayment by the District as determined by the 

14 Contracting Officer due to the reduction(s) in water quantities described in Article 11 

15 and/or Article 12 of this contract shall be applied first to any accrued indebtedness then 

16 due and payable by the District pursuant to this contract Any amount of such 

17 overpayment then remaining shall, at the option of the District, be refunded to the 

18 District or credited upon amounts to become due to the United States from the District 

19 under the provisions hereof in the ensuing Year. Such adjustment shall constitute the 

20 sole remedy of the District or anyone having or claiming to have the right to the use of 

21 any of the water supply provided for herein. 



1-23 



R.O. Draft 6/26-1992 

1 TEMPORARY RFDUCn ONS-RHnrURN FLOWS 

2 . . u 

3 11. (a) The United States shall make all reasonable efforts, consistent with 

4 the most efficient overall operation of the CVP. to deliver CVP water to the District at 

5 the points of delivery identified in Article 5 (a). 

6 (b) The United States may temporarily discontinue or reduce the 

7 quantity of CVP water to be delivered to the District as herein provided for the purposes 

8 of such investigation, inspection, maintenance, repair, or replacement of any of the CVP 

9 facilities or any part thereof necessary for the delivery of water to the District, but so far 

10 as feasible the United States will give the District due notice in advance of such 

11 temporary discontinuance or reduction, except in case of emergency, in which case no 

12 notice need be given; Provided, that the United States shall use its best efforts to avoid 

13 any discontinuance or reduction in such service. Upon resumption of service after such 

14 reduction or discontinuance, and if requested by the District, the United States will, if 

15 possible, deliver the quantity of CVP water which would have been delivered 

16 hereinunder in the absence of such discontinuance or reduction. 

17 (c) The United States reserves the right to all waste, seepage, and 

18 return-flow water derived from water delivered to the District which escapes or is 

19 discharged beyond boundaries of the District's Service Area. Nothing herein shall be 

20 construed as claiming for the United States any right, as waste, seepage, or return flow, 

21 to water being used pursuant to this contract within the District's Service Area by the 

22 District, or those claiming by or through the District. 



1-24 



R.O. Draft 6/26-1992 

1 WATER SHORTAGE AND APPORTIONMENT 

2 12. (a) The United States shall use all reasonable means in its operation 

3 and management of the CVP to make full supplies of CVP water specified in this 

4 contract available to the District during each Year. If, nevertheless, the United States is 

5 unable to make such full supplies available to the District in any Year on account of 

6 drought, errors in operation, or other causes which the Contracting Officer has 

7 determined are beyond the control of the United States, the District shall hold the 

8 United States, its officers, agents and employees harmless from any and all liability 

9 and/or damages arising therefrom, 

10 (b) During any Year in which the Contracting Officer determines that 

11 the United States will be imable to make full supply of CVP water specified in this 

12 contract available to the District, the Contracting Officer shall, to the extent permitted 

13 by applicable law and existing contracts, apportion the available CVP water among the 

14 water users of the CVP by reducing the quantities of CVP water made available to such 

15 users; Provided, that, the percentage reduction applied by the Contracting Officer to the 

16 M&I water made available to the District shall be no greater than the percentage 

17 reduction applied by the Contracting Officer to any other CVP M&I liser, and no 

18 reduction shall be made to M&I water made available to the District unless and until 

19 reductions have also been imposed on irrigation users receiving water from the 

20 integrated Project water supply, irrespective of water allocations as determined by the 

21 Contracting Officer made to prevent undue hardship; and Provided further, that in no 



1-25 



R.O. Draft 6/26-1992 

1 Year of shortage shall the Contracting Officer reduce the quantity of M&I water made 

2 available to the District by more than 25 percent of the forecast of water requiremeats 

3 within the Distrirt Service Area for the upcoming Year. The quantity of CVP water 

4 made available to the District shall be determined in accordance with subdivision (c) of 

5 this Article. 

6 • (c) In order to arrive at the actual quantity of CVP water to be made 

7 available to the District during the upcoming Year of shortage, the percentage reduction 

8 determined pursuant to subdivision (b) shall be applied to the forecast of water 

9 requirements for the Year of shortage as determined in the manner set forth in this 

10 subdivision. The Contracting Officer, prior to imposing a water reduction, shall request, 

11 in writing, from the District a forecast of water requirements within the District Service 

12 Area for the Year of shortage. The District shall prepare and submit said forecast to the 

13 Contracting Officer for approval within the time specified in the request. The quantity 

14 of CVP water to be made available to the District shall be based on the approved 

15 forecast of water requirements within the District's Service Area reduced pursuant to 

16 subdivision (b) above. For the purposes of this Article, the term "water requirements 

17 within the District Service Area," shall be the average quantity of water put to beneficial 

18 use within the District Service Area during the last three Years of water use not affected 

19 by water reductions, adjusted for growth, excluding uses that will continue to be satisfied 

20 from established recycled water and groundwater service. Nothing in this subdivision 

21 shall affect any of the provisions in Article 13. 



1-26 



R.O. Draft 6/26-1992 

1 (d) The quantity of CVP water to be made available to the District 

2 pursuant to subdivisions (b) and (c) above, will be reduced by those water supplies listed 

3 in Exhibit "C that are actually used to satisfy a portion of the forecasted water 

4 requirements within the District's Service Area during the Year of shortage; and will be 

5 further reduced by that quantity of CVP water diverted by the District and stored within 

6 Los Vaqueros during prior Years and withdrawn for use within the District Service Are^ 

7 during the Year of shortage. 

8 (e) In addition to the quantity of CVP water made available to the 

9 District pursuant to subdivisions (b) and (c) of this article, the Contracting Officer may 

10 make additional CVP water available to the District to protect public health and safety. 

11 Requests for this additional CVP water will not be considered unless the District has 

12 developed a drought contingency water conservation plan, acceptable to the Contracting 

13 Officer, and the District is complying with the requirements of this plan. Evaluation of 

14 the requests for additional CVP water will consider other sources of water available to 

15 the District. 

16 EXISTING OR ACQUIRED WATER OR WATER RIGHTS 

17 13. Except as specifically provided, the provisions of this contract shall not be 

18 applicable to or affect water or water rights now oWned or hereafter acquired by the 

19 District or any user of such water in the District Service Area from other than the 

20 United States by the District In addition, this contract shall not be construed as limiting 

21 or curtailing any rights which the District or any water user within the District Service 



1-27 



R.O. Draft 6/26-1992 

1 Area acquires or has available under any other contraa pursuant to the Federal 

2 reclamation laws. 

3 OIJAl.rrY OF WATER 

4 14. In recognition of the importance of water quality to the uses and users of 

5 water in the District and the applicable water quality provisions of the Federal 

6 reclamation laws, and to assist the District in meeting its Los Vaqueros Project goal of 

7 providing high quality water supply to its customers, CVP facilities used to make 

8 available and deliver CVP water to the District pursuant to this contract shall be 

9 operated and maintained to enable the United States to make available and deliver CVP 

10 water to the District in accordance with the water quality standards specified in 

11 subsection 2(b) of the Act of August 26, 1937, (50 StaL 865), as added by Section 101 of 

12 the Act of October 27, 1986, (100 Stat. 3050). The United States is under no obligation 

13 to construct or furnish water treatment facilities to maintain or to better the quality of 

14 CVP water furnished to the District pursuant to this contract. The United States does 

15 not warrant the quality of water to be made available and delivered to the District 

16 pursuant to this contract 

17 WATER AND AIR POLLimON CONTROL . 

18 15. The District, in carrying out this contract, shall comply with all applicable 

19 water and air pollution laws and regulations of the United States and the State of 

20 California, and shall obtain all required permits or licenses from the appropriate 

21 Federal, State or local authorities. 

22 



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R.O. Draft 6/26-1992 

1 OPERATION AND MAINTENANCE OF PROJECT WORKS 

2 16. (a) The District, without expense to the United States, shall O&M the 

3 Project Works in full compliance with the Federal reclamation laws and the terms of this 

4 contract. The provisions of this article shall be implemented consistent with the 

5 Memorandum of Agreement relating to Details of Transfer of Operation and 

6 Maintenance of Contra Costa Canal System, dated June 23, 1972, as it now exists or may 

7 be amended, in such maimer that said Works shall be maintained in a good and efficient 

8 condition. The District shall use all proper methods to assure the economical and 

9 beneficial use of the water delivered by means of said Works. At any time the 

10 Contracting Officer determines the O&M by the District of one or more of the Project 

11 Works is insufficient, the United States may take back the O&M of all or any part of 

12 such Work(s) and the District hereby agrees to surrender possession of said Work(s). 

13 The O&M of such Work(s) so taken back for O&M may shall be retransferred to the 

14 District upon the furnishing by the Contracting Officer of a written notice to the District 

15 ninety (90) days in advance of the intention to retransfer by the United States. Such 

16 retransfer shall not be made until the Project Work(s) has/have been placed in efficient 

17 operating condition; Provided, that for Project Works taken back by the United States 

18 for O&M, the District shall pay the United States quarterly, in advance, sufficient funds, 

19 on the basis of an estimate to be submitted by the Contracting Officer, to finance for the 

20 O&M of such, works. If the actual O&M costs should exceed the estimated costs, the 

21 District shall pay the United States the necessary additional sums of money within sixty 



1-29 



R.O. Drafc 6/26-1992 

1 (60) days after receipt of a bUl submitted by the Contracting Officer to the District. Any 

2 surplus of advances by the District shall be refunded or, at the option of the Contracting 

3 Officer, be applied against any obligation of the District under this contract due at that 

4 time. 

5 (b) No substantial change in any of the Project Works or installation of 

6 District facilities on the lands and rights of way of Project Works shall be made by the 

7 Distrirt without first obtaining the written consent of the Contracting Officer. The 

8 District shall promptly make at its expense any and all repairs or replacements to one or 

9 more of the Project Work(s) which the Contracting Officer determines are necessary for 

10 the proper O&M of such Work(s). If at any time, in the opinion of the Contracting 

11 Officer one or more of the Project Work(s) shall from any cause be in a condition unfit 

12 for service, he may order that the water be turned out and shut off from that Project 

13 Work(s) until, in his opinion, it/they are put in proper condition for service. If the 

14 District neglects or fails to make necessary repairs or replacements, at the option of the 

15 Contracting Officer such repairs or replacements may be made by the United States and 

16 the cost therefor charged to the District. The District shall repay such costs as a 

17 miscellaneous cost pursuant to Article 18 hereoL The District at its own expense shall 

18 repair any damage to the Project Works resulting from negligence of its officers, 

19 employees, or agents. 
20 



1-30 



R.O. Draft 6/26-1992 

1 (c) From time to time the Contracting Officer, without cost to the 

2 District, may make a review of maintenance of the Project Works in order to assist the 

3 District in determining the condition of those facilities and the adequacy of the 

4 maintenance program. The review may include any or all of the Project Works. A 

5 report of each such review, including recommendations, if any, shall be prepared and a 

6 copy shall be furnished to the District. If deemed necessary by the Contracting Officer 

7 or when requested by the District, jui inspection of any of the Project Works and of the 

8 District's books and records relating thereto may be made to ascertain whether the 

9 requirements of this contract are being satisfactorily performed by the District or to 

10 assist the District in solving specific problems. Any such inspection shall, except in a 

11 case of emergency, be made after written notice to the District and the actual cost 

12 thereof shall be paid by the District to the United States as a miscellaneous cost 

13 pursuant to Article 18 hereof. District representatives may participate in either the 

14 review or inspection. 

15 (d) The District shall have the right to abandon one or more of the 

16 Project Works with the prior written approval of the Contracting Officer; Provided, that 

17 abandonment of one or more of the Project Works shall not relieve the District of its 

18 obligation to repay the capital cost plus interest as appropriate of such Project Work(s) 

19 facilities less any disposal or salvage value which may be realized. 
20 



1-31 



R.O. Drafc 6/26-1992 

1 (e) If and when the Distrirt fuUy repays the United Sutes the costs of 

2 one or more of the Project Works and the ownership of such Project Works is 

3 transferred to the District, the provisions of subdivisions (a), (b), (c), and (d) of this 

4 Article and subdivision (a) of Article 17 shall no longer apply to such work(s). 

5 rONVEYANrP OF NON-P R OTFrr WATER 

6 17. The District may use Project Works to convey non-project water, subject to 

7 each of the following conditions: 

8 (a) such conveyance shall not interfere with deliveries of water hereunder; 

9 (b) Non-project water for irrigation use shall be utilized in accordance with the 

10 applicable acreage limitation provisions of the Federal reclamation laws; 

11 (c) CVP project use power shall not be used to pump or convey non-project 

12 water; 

13 (d) The United States shall not incur any liability or imreimbursed cost or 

14 expense thereby; 

15 (e) The quantities of non-projea water introduced into and conveyed through 

16 the Project Works shall be measured or otherwise determined by the District in a 

17 manner consistent with Article 5 of this contract, acceptable to the Contracting Officer 

18 and at no cost to the United States; 

19 (0 The rate(s) the District is to pay to the United States for conveying non- 
20 project water through Project Works shall be determined annually by the United States 
21 in accordance with the applicable provisions of Federal law, including but not limited to 



1-^2 



R.O. Draft 6/26-1992 

1 the Warren Act of February 21, 1911 (36 Stat 935), as amended and supplemented, 

2 associated regulations and the then-current applicable Federal ratesetting policies. 

3 DISTRICT TO PAY CERTAIN MISCELLANEOUS COSTS 

4 RELATING TO PROJECT WORKS 
5 

6 18. In addition to all other payments to be made by the District under this 

7 contact, the District shall repay to the United States, within sbcty (60) days after receipt 

8 of a bill and detailed statement submitted by the Contracting Officer to the District for 

9 such specific items of direct cost incurred by the United States for work associated with 

10 this contract normally charged by the United States plus a percentage of such direct costs 

11 for administrative and general overhead in accordance with applicable Bureau of 

12 Reclamation policy and procedures. 

13 EMERGENCY RESERVE FUND 

14 19. (a) The District shall accumulate and maintain a reserve fund, as set 

15 forth in subdivision (b) below, which the District shall keep available to pay O&M costs 

16 incurred during periods of special stress caused by damaging droughts, storms» 

17 earthquakes, floods, or other emergencies threatening or causing interruption of water 

18 service. 

19 (b) The District shall establish a reserve fund of not less than 

20 $1.000.000 in a Federally insured interest- or dividend-bearing account, or investments 

21 in securities guaranteed by the Federal Government; Provided , that the money so 

22 deposited or invested shall be available within a reasonable time to meet expenses for 



1-33 



R.O. Draft 6/26-1992 

1 the purposes idenUfied in subdivision (d) of this Article. Whenever said reserve fund is 

2 reduced below one million Dollars by expenditures therefrom, it shall be restored to that 

3 amount by accumulation of annual deposits at a minimum of $250,000. The interest 

4 earnings shall continue to accumulate and be retained as part of the reserve fund except 

5 when required to meet expenditures pursuant to subdivisions (a) and (d) of this Artxcle. 

6 (c) By written agreement between the District and the Contracting 

7 Officer, the basic amount of the reserve fund may be adjusted to account for risk and 

8 uncertainty stemming from the size and complexity of the Project Works, the size of the 

9 District's annual O&M budget and O&M costs not contemplated when this contract was 

10 executed. 

11 (d) The District may withdraw money from the reserve fund only for 

12 meeting unusual O&M costs incurred during periods of special stress as described in 

13 subdivision (a) above, and unforeseen extraordinary O&M costs, unusual or 

14 extraordinary repair or replacement costs, and betterment costs (in situations where 

15 recurrence of severe problems can be eliminated) during such periods of special stress. 

16 The District shall notify the Contracting Officer of any e;q)enditure from the reserve fund 

17 pursuant to this subdivision. 
18 



1-34 



R.O. Draft 6/26-1992 

1 TRANSFER OF TITLE TO PROJECT WORKS 

2 20. Upon repayment of the all outstanding capitalized costs of one or more of 

3 the Project Works, and upon appropriate authorization by Congress, all rights, title and 

4 interest in and to the relevant Project Work(s) shall be transferred to the District 

5 PERFORMANCE OF WORK WITH CXDNTRIBUTED FUNDS 

6 21. (a) Pursuant to the Act of March 4, 1921 (41 StaL 1367, 1404), the 

7 Contracting Officer may accept funds contributed by the District to finance any 

8 authorized construction work on the CVP facilities not otherwise provided for by this 

9 contract for which funds may not be available. Pursuant to the Act of January 12, 1927 

10 (44 Stat. 957, 43 U.S.C. § 397a), the Contracting Officer may also accept funds 

11 contributed by the District to finance any authorized operations and maintenance work 

12 on the CVP facilities not otherwise provided for by this contract for which funds may not 

13 be available. When the undertaking of such work is approved, funds therefor shall be 

14 advanced by the District as may be directed by the Contracting Officer and there shall 

15 be submitted to the Contracting Officer a certified copy of the resolution of the Board of 

16 Directors of the District describing the work to be done and authorizing its performance 

17 with contributed funds. 

18 (b) After completion of any work so undertaken the District shall be 

19 furnished with a statement of the final cost thereof and any unexpended balance of funds 

20 shall be refunded to the District or applied as otherwise directed by the District, and the 

21 amount by which the cost of such work exceeds the amount of the funds advanced by the 



1-35 



R.O. Draft 6/26-1992 

1 District therefor shall be paid by the District to the United States as the Contracting 

2 Officer may direct 

3 GENERAL OBLIGATION-BENEFITS CONDITIONED UPON PAYMENT 

4 22. (a) The obligation of the District to pay the United States as provided 

5 in this contract is a general obligation of the District notwithstanding the manner in 

6 which the obligation may be distributed among the District's water users and 

7 notwithstanding the default of individual water users in their obligations to the District 
8 

9 (b) The payment of charges becoming due hereunder is a condition 

10 precedent to receiving benefits under this contract The United States shall not make 

11 water available to the District through CVP facilities during any period in which the 

12 District may be in arrears in the advance payment of water rates due the United States 

13 or in arrears for more than 12 months in the payment of any construction charges due 

14 the United States. The District shall not furnish water made available pursuant to this 

15 contract for lands or parties which are in arrears in the advance payment of water rates 

16 or in arrears more than 12 months in the payment of construction charges as levied or 

17 established by the District 
18 

19 COMPLIANCE WITH RECLAMATION LAWS 

20 

21 23. The parties agree that the delivery of irrigation water or the use of the 

22 federal facilities pursuant to this contract is subject to Reclamation law, as amended and 

23 supplemented, including, but not limited to, the Reclamation Reform Act of 1982 (96 

24 Stat 1263; 43 U.S.C. § 390aa, et seq ). 
25 

26 BOOKS. RECORDS AND REPORTS 

27 

28 24. The District shall establish and maintain accounts and other books and 

29 records pertaining to administration of the terms and conditions of this contract, 

30 including: the District's financial transactions, water supply data, CVP operation, 

31 maintenance and replacement logs, and CVP land and right-of-way use agreements; the 

32 water users' land-use (crop census), landownership, land-leasing and water-use data'; and 

33 other matters that the Contracting Officer may require. Reports thereon shall be 

34 furnished to the Contracting Officer in such form and on such date or dates as the 

35 Contracting Officer may require. Subject to applicable Federal laws and regulations, 

36 each party to this contract shall have the right during office hours to examine and make 

37 copies of the other party's books and records relative to matters covered by this contract 
38 

39 



1^ 



R.O. Drafc 6/26-1992 

1 CONTINGENT ON APPROPRIATION OR ALLX^TMRNT OF FUNDS 

2 

3 25. The expenditure or advance of any money or the performance of any 

4 obligation of the United States under this contract shall be contingent upon 

5 appropriation or allotment of funds. Absence of appropriation or allotment of funds 

6 shall not relieve the District from any obligations under this contract. No liability shall 

7 accrue to the United States in case funds are not appropriated or allotted. 
8 

9 RULES. REGULATIONS AND DETERMINATIONS 

10 

11 26. (a) The parties agree that the delivery of water or the use of Federal 

12 facilities pursuant to this contract is subject to Reclamation law, as amended and 

13 supplemented, and the rules and regulations promulgated by the Secretary of the Interior 

14 under Reclamation law; Provided, that nothing herein shall be construed as a waiver, by 

15 the District, to contest any modification in such rules and regulations, and of the right to 

16 seek just compensation for the taking of any rights granted under this contract 

17 

18 (b) The Contracting Officer shall have the right to make 

19 determinations necessary to administer this contract that are consistent with the 

20 expressed and implied provisions of this contract, the laws of the United States and the 

21 State, and the rules and regulations promulgated by the Secretary of the Interior. Such 

22 determinations shall be made in consultation with the District. 
23 

24 OFFICIALS NOT TO BENEFIT 

25 

26 27. No member of, or delegate to Congress, Resident Commissioner, or official 

27 of the District shall benefit from this contract other than as a water user or landowner in 

28 the same manner as other water users or landowners. 
29 

30 



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R.O. Draft 6/26-1992 

1 NOTICES 

2 

3 28. Any notice, demand, or request authorized or required by this contract 

4 shall be deemed to have been given, on behalf of the District, when mailed, postage 

5 prepaid, or delivered to the Regional Director, Mid-Pacific Region, Bureau of 

6 Reclamation, 2800 Cottage Way. Sacramento. California 95825-1898, and on behalf of 

7 the United States, when mailed, postage prepaid, or delivered to the Board of Directors 

8 of the Contra Costa Water District, PO Box H20, Concord CA 94524. The designation 

9 of the addressee or the address may be changed by notice given in the same manner as 
10 provided in this article for other notices. 

12 ASSIGNMENT UMTTED-SIJCCESSORS AND ASSIGNS OBLIGATED 

13 

14 29. The provisions of this contract shall apply to and bind the successors and 

15 assigns of the parties hereto, but no assignment or transfer of this contract or any right 

16 or interest therein shall be valid until approved in wri.ting by the Contracting Officer. 

17 

18 EQUAL OPPORTUNITY 

19 

20 30. During the perfonnance of ±is contract, the District agrees as follows: 

21 

22 (1) The District will not discriminate against any employee or applicant 

23 for employment because of race, color, religion, sex, or national origiiL The 

24 District will take affirmative action to ensure that applicants are employed, and 

25 that employees are treated during employment, wi±out regard to their race, color, 

26 religion, sex, or national origin. Such action shall include, but not be Umited to, 

27 the following: Employment, upgrading, demotion, or transfer; recruitment or 

28 recruitment advertising; layoff or termination; rates of pay or other forms of 

29 compensation; and selection for training, including apprenticeship. The District 

30 agrees to post in conspicuous places, available to employees and applicants for 

31 employment, notices to be provided by the Contracting Officer setting forth the 

32 provisions of this nondiscrimination clause. 
33 

34 (2) The District will, in all soUcitations or advertisements for employees 

35 placed by or on behalf of the District, state that all qualified applicants will 

36 receive consideration for employment without discrimination because of race, 

37 color, religion, sex, or national origin. 
38 

39 (3) The District will send to each labor union or representative of 

40 workers with which it has a collective bargaining agreement or other contract or 

41 understanding, a notice, to be provided by the Contracting Officer, advising the 

42 said labor union or workers' representative of the District's commitments under 

1-38 



R.O. Draft 6/26-1992 

1 Section 202 of Executive Order 11246 of September 24, 1965, and shall post 

2 copies of the notice in conspicuous places available to employees and applicants 

3 for employment. 
4 

5 (4) The District will comply with all provisions of Executive Order No. 

6 11246 of September 24, 1965, as amended, and of the rules, regulations, and 

7 relevant orders of the Secretary of Labor. 

8 

9 (5) The District will furnish all information and reports required by said 

10 amended Executive Order and by the rules, regulations, and orders of the 

11 Secretary of Labor, or pursuant thereto, and will permit access to its books, 

12 records, and accounts by the Contracting Officer and the Secretary of Labor for 

13 purposes of investigation to ascertain compliance with such rules, regulations, and 

14 orders. 
15 

16 (6) In the event of the District's noncompliance with the 

17 nondiscrimination clauses of this contract or with any of the said rules, 

18 regulations, or orders, this contract may be cancelled, terminated, or suspended, in 

19 whole or in part, and the District may be declared ineligible for further 

20 government contracts in accordance with procedures authorized in said amended 

21 Executive Order, and such other sanctions may be imposed and remedies invoked 

22 as provided in said Executive Order, or by rule, regulation, or order of the 

23 Secretary of Labor, or as otherwise provided by law. 
24 

25 (7) The District will include the provisions of paragraphs (1) through 

26 (7) in every subcontract or purchase order unless exempted by the rules, 

27 regulations, or orders of the Secretary of Labor issued pursuant to Section 204 of 

28 said amended Executive Order, so that such provisions will be binding upon each 

29 subcontractor or vendor. The District will take such action with respect to any 

30 subcontract or purchase order as may be directed by the Secretary of Labor as a 

31 means of enforcing such provisions, including sanctions for noncompliance: 

32 Provided, however, that in the event the District becomes involved in, or is 

33 threatened with, litigation with a subcontractor or vendor as a result of such 

34 direction, the District may request the United States to enter into such litigation 

35 to protect the interests of the United States. 
36 

37 CHARGES FOR DELINQUENT PAYMENTS 
38 

39 31. (a) The District shall be subject to interest, administrative and penalty 

40 charges on delinquent installments or payments. When a payment is not received by the 

41 due date, the District shall pay an interest charge for each day the payment is delinquent 

42 beyond the due date. When a payment becomes 60 days delinquent, the District shall pay 



1-39 



R.O. Drafc 6/26-1992 

1 an administrative charge to cover additional costs of billing and processing the 

2 delinquent payment. When a payment is delinquent 90 days or more, the District shall 

3 pay an additional penalty charge of six percent (6%) per year for each day the payment 

4 is delinquent beyond the due date. Further, the District shall pay any fees incurred for 

5 debt collection services associated with a delinquent payment 

6 

7 (b) The interest charge rate shall be the greater of the rate 

8 prescribed quarterly in the Federal Register by the Department of the Treasury for 

9 application to overdue payments, or the interest rate of one-half percent (0.5%) per 

10 month prescribed by Section 6 of the Reclamation Project Act of 1939 (Public Law 

11 76-260). The interest charge rate shall be determined as of the due date and remain 

12 fixed for the duration of the delinquent period. 

13 

14 (c) When a partial payment on a delinquent account is received, the 

15 amount received shall be applied, first to the penalty, second to the administrative 

16 charges, third to the accrued interest, and finally to the overdue payment 

17 

18 COMPLIANCE WITH CIVIL RIGHTS LAWS AND REGULATIONS 

19 

20 32. (a) The District shall comply wi± Title VI of the Civil Rights Act of 

21 1964 (42 U.S.C. § 2000d), Section 504 of the RehabiHtation Act of 1975 

22 (P.L. 93-112, as amended), the Age Discrimination Act of 1975 (42 U.S.C. § 6101, 

23 ej isa. ) and any o±er applicable civil rights laws, as well as with their respective 

24 implementing regulations and guidelines imposed by the U.S. Department of the Interior 

25 and/or Bureau of ReclamatioiL 
26 

27 (b) These statutes require that no person in the United States shall, on 

28 the grounds of race, color, national origin, handicap, or age, be excluded from 

29 participation in, be denied the benefits of, or be otherwise subjected to discrimination 

30 under any program or activity receiving financial assistance from the Bureau of 

31 Reclamation. By executing this contract, the District agrees to immediately take any 

32 measures necessary to implement this obligation, including permitting officials "of the 

33 United States to inspect premises, programs, and documents. 
34 

35 (c) The District makes this agreement in consideration of and for the 

36 purpose of obtaining any and all federal grants, loans, contract, property discounts or 

37 other federal financial assistance extended after the date hereof to the District by the 

38 Bureau of Reclamation, including installment payments after such date on account of 

39 arrangement for federal financial assistance which were approved before such date. The 

40 District recognizes and agrees that such federal assistance will be extended in reliance on 

41 the representations and agreements made in this article, and that the United States 

42 reserves the right to seek judicial enforcement thereof. 

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R.O. Draft 6/26-1992 

1 PRIVACY ACT COMPLIANCE 

2 

3 33. (a) The District shall comply with the Privacy Act of 1974 (5 U.S.C. § 

4 552a) (the Act) and the Department of the Interior rules and regulations under the Act 

5 (43 C.F.R. 2.45 et seq.) in maintaining landholder acreage certification and reporting 

6 records, required to be submitted to the District for compliance with sections 206 and 

7 228 of the Reclamation Reform Act of 1982 (96 Stat 1266), and pursuant to 43 C.F.R. 

8 426.10. 
9 

10 (b) With respect to the application and administration of the criminal 

11 penalty provisions of the Act (5 U.S.C. § 552a(i)), the District and the Districts 

12 employees responsible for maintaining the certification and reporting records referenced 

13 in (a) above are considered to be employees of the Department of the Interior. See 5 

14 U.S.C. § 552a(m). 
15 

16 (c) The Contracting Officer or a designated representative shall provide 

17 the District with current copies of the Interior Department Privacy Act regulations and 

18 the Bureau of Reclamation Federal Register Privacy Act System of Records Notice 

19 (Acreage Limitation-Interior, Reclamation-31) which govern the maintenance, 

20 safeguarding, and disclosure of information contained in ±e landholders certification and 

21 reporting records. 
22 

23 (d) The Contracting Officer shall designate a full-time employee of the 

24 Bureau of Reclamation to be the System Manager who shall be responsible for making 

25 decisions on denials pursuant to 43 C.F.R. 2.61 and 2.64 amendment requests pursuant 

26 to 43 C.F.R. 2.72. The District is authorized to grant requests by individuals for access 

27 to their own records. 
28 

29 (e) The District shall forward promptly to the System Manager each 

30 proposed denial of access under 43 C.F.R. 2.64, and each request for amendment of 

31 records filed under 43 C.F.R. 2.71; notify the requester accordingly of such referral; and 

32 provide the System Manager with information and records necessary to prepare an 

33 appropriate response to the requester. These requirements do not apply to individuals 

34 seeking access to their own certification and reporting forms filed with the District 

35 pursuant to 43 C.F.R. $ 426.10 unless the requestor elects to cite the Privacy Act as a 

36 basis for the request. 

37 
38 



1-41 



R.O. Drafc 6/26-1992 

1 CONFIRMATION OF CONTRACT 

2 34. The District, after the execution of this contract, shall promptly seek to 

3 secure a decree of a court of competent jurisdiction of the State of California, confirming 

4 the execution of this contract The District shall furnish the United States a certified 

5 copy of the final decree, the validation proceedings, and ail pertinent supporting records 

6 of the court approving and confirming this contract, ajid decreeing and adjudging it to be 

7 lav/ful, valid, and binding on the District This contract shall not be binding on the 

8 United States until such final decree has been secured. 

9 // 

10 // 

11 // 

12 // 

13 // 

14 // 

15 // 

16 // 

17 // 

18 // 

19 // 

20 // 

21 // 



1-42 



R.O. Draft 6/26-1992 

1 WATER CONSERVATION 

2 35. The District shall develop an effective water conservation program 

3 acceptable to the Contracting Officer. The water conservation program shall contain 

4 definite water conservation objectives, appropriate economically feasible water 

5 conservation measures, and time schedules for meeting those objectives. At subsequent 

6 6- Year intervals, the District shall submit a report on the results of the program to the 

7 Contracting Officer for review. Based on the conclusions of the review, the Contracting 

8 Officer and District shall consult and agree to continue or to revise the existing water 

9 conservation program. 

10 CPIANGES IN DISTRICTS ORGANIZATION 

11 36. While this contract is in effect, no change may be made in the 

12 District's organization, by inclusion or exclusion of lands, dissolution, consolidation, 

13 merger or otherwise, except upon the Contracting Officer's written consent Such 

14 consent is required to ensure that the District retains its capacity to perform the 

15 obligations and make the payments set forth herein and to ensure compliance with the 

16 applicable provisions of Federal reclamation laws including but not limited to Section 8 

17 of the Act of June 17, 1902 (32 Stat 390; 43 U.S.C. §§ 372, 383) and the Reclamation 

18 Reform Act of October 12. 1982 (96 Stat 1263; 43 U.S.C § 390aa. et seq.) 
19 



1-43 



1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 



R.O. Drafc 6/26-L992 

IN WITNESS WHEREOF, the parties hereto have executed this contract as of 
the day and year first hereinabove written. 

THE UNITED STATES OF AMERICA 



By. 



(SEAL) 



Attest: 



Secretary 
jdccwd.con 



Regional Director, Mid-Pacific Region 
Bureau of Reclamation 



CONTRA COSTA COUNTY WATER DISTRICT 



By. 



President 



1-44 



R.O. Draft 6/26-1992 
EXHIBIT A 



1992 Water Rates Per Acre-Foot (rounded) for Amendatory 
Contract No. I75r-3401 Contra Costa Water District 



$5.52 



$2.37 



0.30 



$2.67 



$5.67 



$8.35 





Central Va 


lley 


Project 


Los Vaqueros 
Water 




IRRIGATION 




M&I 


M&I 


O&M Rate: 

Water Marketing 
Storage 
Conveyance 
Conveyance Pumping 
Direct Pumping 
San Luis Drain 


$0.66 
3.73 

1.13 




$0.94 
3.60 . 

1.13 


$0.94 
N/A 
N/A 
N/A 
1.13 
N/A 



$2.07 



$1.78 


N/A 


5.92 


N/A 




N/A 




N/A 


0.65 


$0.65 




N/A 



$0.65 



Total O&M Rate 

Capital Components 

Deferred Interest 
Storage 
Conveyance 
Conveyance Pumping 
Direct Pumping 
San Luis Drain 

Total Capital Rate 

Deficit Rate: 

Non-Interest Bearing 
Interest Bearing 

Total Deficit Rate 



Cost of Service Rate 

M&I Surcharge 
199 2 water rates 

Full Cost Rates as defined in Reclamation Reform Act (96 Stat. 1263) 

202(3) $34.89 N/A N/A 

205(a)(3) $41.00 N/A N/A 

1-45 

* To be determined by the Contracting Officer prior to the 
effective date of this amendatory contract 



$19.60 
0.34 


$6.15 


N/A 
N/A 


$19.94 


$6.15 




$28.14 


$20.17 


$2.72 


N/A 


* 


N/A 


$28.14 


* 


$2.72 



EXHIBIT B 
PAGE 1 OF 3 



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BXIIIBIT B 
PAGE 2 OF 3 






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1-47 



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EXHIBIT B 
PAGE 3 OF 3 



R.O. 



Draft 6/26-1992 



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1-48 



R.O. Draft 6/26-1992 



EXHIBIT C 



CONTRA COSTA WATER DISTRICT AMENDATORY CONTRACT I75r-3401 



WATER SUPPLIES FOR WHICH THE ACTUAL AVAILABILITY 
WILL BE DEDUCTED FROM CVP WATER ALLOCATION TO 
THE DISTRICT IN YEARS OF SHORTAGE, PURSUANT TO 
ARTICLE 12, SUBDIVISION (d) 



Water Right Holder Water Right Application No. 



City of Antioch S 9352 
Contra Costa Water 

District A 5941 (P 3167, L 10514) 

A 27893 (P 19856) 
Gaylord Container A 17001 (P 19418) 



Note: S = Statement of Use 



1-49 



1-50 



Attachment 2. Effects of Revised Project Operations on 
Delta Diversions 



2-1 



2-2 



TABLE OF CONTENTS 

Page 

Description of Additional Operation Studies 2-5 

Graph of Average Monthly CCWD Delta Diversions 2-9 

Tables of CCWD Delta Diversions 2-10 

Tables of Net Delta Outflow 2-14 

Tables of QWEST 2-18 

Tables of Chipps Island Salinity 2-22 

Tables of Total Delta Exports 2-28 

Graph of End-of-Month CVP Reservoir Storage 2-32 

Tables of End-of-Month Storage in CVP Reservoirs 2-33 

Project Performance for D1485 and D1485 + NMFS + USFWS CVP-OCAP 
Biological Opinion Standards 2-37 

Graph of Reservoir Volume Variation 1922-1991 2-39 

Graph of Delivered Chlorides (Cumulative Probability) 2-40 

Tables Showing Comparison Between 57-Year and 70- Year Studies 2-41 

Graph of Sacramento 4-River Index Variation 1922-1991 2-42 

Comparison with Proposed EPA 2ppt Standard at Chipps Island 2-43 



Note: Tables consist of absolute values for the No-Action case and the differences between 
the Preferred Alternative and No Action case. Differences in Chipps Island salinity 
are also presented as tables of percentage differences. 



2-3 



2-4 



Description of Additional Operations Studies 

In response to reviewer's comments on the Los Vaqueros Project 
Draft Stage 2 EIR/EIS, CCWD has examined the project for a variety 
of current and potential water quality and flow standards. The 
operation studies have also been extended to incorporate the new 
70-year hydrology (1922-1991). 

Since publication of the Draft Stage 2 EIR/EIS, the California 
State Water Resources Control Board has introduced a new approach 
for setting water quality and flow standards. Draft Decision 1630 
water quality standards were not implemented by the SWRCB. 
However, under the Endangered Species Act, the National Marine 
Fisheries Service (NMFS) has issued a CVP-OCAP Biological Opinion 
on Winter-Run Salmon (February 12, 1993) and the United States Fish 
and Wildlife Service (USFWS) has issued a CVP-OCAP Biological 
Opinion on Delta Smelt (May 26, 1993). The United States 
Environmental Protection Agency (EPA) has also proposed standards 
based on the location of the 2 ppt bottom salinity. 

NMFS has also issued a Los Vaqueros Project Biological Opinion for 
winter run salmon (March 18, 1993). Additionally, the US Fish and 
Wildlife Service has issued a Biological Opinion on Los Vaqueros 
Project operations for Delta smelt (September 9, 1993). 

The operation study results presented in this Attachment reflect 
Central Valley flows and Delta salinities for two different cases: 

(1) SWRCB Decision 1485, 

(2) D-1485 with both the NMFS CVP-OCAP biological opinion for 
winter run salmon (February 12, 1993) and conditions based on 
the 1993 USFWS CVP-OCAP biological opinion for Delta smelt 
(May 26, 1993) . 

In both cases, operation of the Los Vaqueros project was based upon 
operations rules from: 

(a) NMFS LVP biological opinion for winter run salmon 
(March 18, 1993) , 

(b) USFWS LVP biological opinion for Delta smelt 
(September 9, 1993) . 

Limited analyses of the operation of the Los Vaqueros Project under 
Draft D-1630 were also carried out. However, the NMFS CVP-OCAP 
biological opinion and USFWS 1993 CVP-OCAP biological opinion both 
incorporated major features from SWRCB Draft D-1630, in particular 
limitations on QWEST for November through August. Results from the 
Draft D-1630 analyses are similar to those for D1485+NMFS+USFWS 
CVP-OCAP BO. 



2-5 



The following operation rules were used in the Los Vaqueros 
Operation studies reported in this attachment: 

(1) Existing CCWD demands: 117.6 TAF in non-critical years, 130.7 
TAF in critical years. (Source: Montgomery-Watson, Consulting 
Engineers) . 

(2) Limited CCWD direct diversion in April. In April, CCWD 
service area demands were satisfied by releases from the Los 
Vaqueros Reservoir, provided emergency storage requirements 
were still met. 

(3) No diversions to storage March 15 through May 31 (NMFS LVP 
BO on winter run salmon and USFWS LVP BO on Delta smelt) . 

(4) The reservoir was not filled if the chloride concentration at 
the proposed Old River intake exceeded 50 mg/1 chloride. 

(5) The reservoir can be filled September through December without 
restriction. The reservoir can be filled January and June 
through August if the 2 ppt isohaline was at or west of 
Collinsville . The reservoir can be filled February through 
March 15 if the 2 ppt isohaline was at or west of Chipps 
Island . 

(6) One source of filling water was Los Vaqueros Water Right 20245 
water (only available November through June when surplus flow 
is available, but further restricted by rule (3) above, 
according to NMFS Los Vaqueros Project Biological Opinion on 
Winter Run Salmon) . The other source is CVP rediversion 
water. As per rule (4) above, this was assumed available 
without restriction September through December. However, for 
January through March 14, and June through August, 
availability of CVP rediversion v;ater was assumed to be 
restricted when the CVP was making releases or limiting 
exports to meet the requirements of the CVP-OCAP biological 
(for example, limitations on QWEST). 

(7) Total CCWD diversions of CVP water from the Delta were limited 
to 195 TAF, March through February. 

(8) Water qualities at the existing Rock Slough intake and 
proposed Old River intake were based on monthly averages from 
Fischer Delta model simulations (fixed chloride operation 
studies) . 



The operation studies show that, regardless of hydrologic period 
and water quality and flow standards, the project does not result 
in significant net increases in CCWD diversions from the Delta and 
the diversions in any one year do not deviate significantly from 
the average diversions. Increases in diversions generally occur in 
wet years following dry years, and decreased diversions are common 
in dry years. Under D-1485, most of the reservoir filling would 
occur in June, July and August. Under D1485+NMFS+USFWS CVP-OCAP 
BO, the QWEST limitations for June, July and August limit the 
availability of CVP rediversion water. The main filling period 
shifts away from Spring into the Fall. It is important to remember 
that in all cases, Los Vaqueros Reservoir filling only occurs when 



2-6 



the Delta inflows and outflows are large enough to produce good 
guality water at the Old River intake (50 mg/l chlorides). 

The operations studies again show that the project effects on Delta 
outflows, reverse flows (negative QWEST) and total Delta exports 
are very small, regardless of the assumptions on hydrology and 
Delta standards. The operations studies also suggest that, the 
shift in timing of diversions with the Los Vaqueros Project may 
result in a small increase in the average CVP end-of-month 
reservoir storage from November through August. 

Note that under D-1485, the limited CCWD Delta diversions in April 
(average of 0.9 TAF with the project) are reflected in a net 
decrease in total Delta diversions in April (average of -5 TAF) . 
However, under the current NMFS and USFWS OCAP biological opinions, 
the CVP and SWP would likely conduct operations as closely as 
possible within their QWEST limitations. In the present operations 
studies, April was chosen to represent the 30-day period when 
releases are made from the Los Vaqueros Reservoir releases and all 
CCWD Delta diversions cease. The current CVP-OCAP biological 
opinions require a minimum QWEST of cfs in April. The present 
operation studies with D1485+NMFS+USFWS OCAP BO standards in the 
Delta, indicate that the QWEST restriction is the limiting factor 
so increased pumping at the Tracy pumping plant offsets the April 
reductions in CCWD diversions and that there is often no net 
decrease in total Delta diversions. 

The change in project diversions (limited to 200 cfs) do not have 
a significant effect on Chipps Island salinity. 

The operations studies suggest that with the preferred alternative, 
the Contra Costa Water District will be able to meet its delivered 
water quality goal of 65 mg/l more than 94% of the time compared to 
only 65% without the project. The operations studies also suggest 
that with the preferred alternative, the District would be able to 
stop all Delta diversions in April, 83% of the time. 

Adding current hydrology to the sequence (1979-1991) changes the 
sample statistics slightly, but does not alter the conclusions. 
These results demonstrate that, regardless of assumptions 
concerning Delta standards and the length of the hydrologic record, 
the Los Vaqueros Project has virtually no effect on Delta flows and 
salinity, and that the conclusions based upon the earlier studies 
are unchanged. The average Sacramento 4-River index for 1922-1978 
(17.1 MAF) is almost the same as the 1922-1991 average (17.2 MAF) . 
From 1922 to 1937, runoff from the Sacramento River basin tended to 
be below average, but this was compensated by a net above average 
Sacramento River basin runoff from 1938 to 1978. From 1979 to 
1986, there was a net above average runoff but this was compensated 
by the net below average runoff during the drought period 
1987-1991. 



2-7 



The final table in this attachment is a comparison of the Chipps 
Island salinities from one of the operations studies with the 
proposed EPA 2 ppt isohaline standards. The operation study chosen 
for this comparison assumes D1485 with the NMFS and USFWS CVP-OCAP 
biological opinions (i.e. QWEST standards in place) but does not 
specifically attempt to meet EPA's proposed 2 ppt bottom isohaline 
standards at Roe Island, Chipps Island or Collinsville. The 
operation study suggests that v/ith the existing water quality and 
flow standards, the CVP and SWP should be able to meet the 2ppt 
standard at Chipps Island during v/et, above normal and most below 
normal years without additional releases. However, the standard 
would not be met in most dry and critical years without either 
additional releases or reductions in exports. Note that this 
analysis is based on monthly-averaged flows and salinities, so 
individual days of compliance within a given month could not be 
determined . 

The USFWS Los Vaqueros biological opinion on Delta Smelt 
(September 9, 1993) limits filling of the Los Vaqueros Reservoir 
based on the location of the 2ppt bottom isohaline at Chipps 
Island and Collinsville. This will further ensure that the Project 
will not adversely affect the designated beneficial uses of the 
Bay/Delta estuary. 



2-8 



CCWD Delta Diversions 

Existing Demands, D-1485 



Diversions (TAF) 




Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep All 

.^^^^ ^ ^^ Months 

Month (1922-1991) 



CCWD gds 08/31/93 



CCWD Delta Diversions 
Existing Demands, D-1485 + NMFS + USFWS OCAP BO 



Diversions (TAF) 




Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep All 

Months 
Month (1922-1991) 



CCWD gds 08/31/93 



2-9 



CCUO Delta Diversions (TAF) 100BH 

Existing Level of Demand, No-Action; D-1485 

YEAR OCT NOV DEC JAN FEB MAR APR HAY JUN JUL AUG SEP TOTAL 

1922 10.69 8.83 7.23 6.05 A.65 4.95 5.33 11.00 3.60 5.54 6.92 2.78 7.57 

1923 10.69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 3.60 5.54 6.92 2.78 17.57 

1924 10.69 8.83 7.23 6.05 4.65 9.87 8.68 12.02 2.07 6.19 3.68 3.50 30.67 

1925 12.01 9.37 8.86 7.13 7.29 4.95 5.33 11.00 3.60 5.54 6.92 2.78 7.57 
.« ,- » „, -, -., ^ oc / ic , an <; 71 11 nn 13-60 15.54 16. 9<; l^.^O 11^.3/ 



1926 10.69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 3.60 .4 6.9 2.^8 yry 

1927 10.69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 3.60 5.54 6.92 2.78 7.5^ 

1928 10.69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 3.60 5.54 6.92 2.78 17.57 

1929 10.69 8.83 7.23 6.05 4.65 9.87 8.68 12.02 12.07 16.19 3.68 3.50 30.6^ 

1930 12.01 9.37 8.86 7.13 7.29 4.95 5.33 11.00 .60 .4 6.92 .78 57 



^ ;^:^9 8:83 7.TZ 6.0t HI V.I7 S.ii ^2.02 12.07 16.19 13.68 13.50 130.67 

1932 12.01 9.37 8.86 7.13 7.29 4.95 5.33 11.00 3.60 5.54 6.92 2.78 17.57 

1933 10.69 8.83 7.23 6.05 4.65 9.87 8.68 12.02 12.07 16.19 3.68 3.50 30.6^ 

934 12 01 9 37 8 86 7.13 7.29 9.87 8.68 12.02 12.07 16.19 13.68 3.50 30.67 

935 Wo] lz7 8.86 7.13 7.29 4.95 5.33 11.00 13.60 15.54 16.9 .8 .7 
107A in M B fl^ 7 23 6 05 4 65 4 95 5.33 11.00 13.60 15.54 16.92 12.78 lU.Si' 

97 111 l:ll T-.ll tfs dl 4:95 5.33 11.00 13.60 15.54 16.92 12.78 117. 

107« in M B R3 7 23 6 05 4 65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.5^ 

99 : ' 8:83 7:23 tol dl 9.87 8.68 12.02 12.07 16.19 13.68 13.50 1 0.6 

104(1 1? 01 9 37 8 86 7 13 7 29 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

94? o'69 883 7'23 605 4 65 4 95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

942 0I9 I'll ill 60 4I 495 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

94I SI9 ill ill 605 4:65 495 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

]ld \oil ill 7:23 605 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

94 10:69 1:83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.9 .78 7 

1946 10.69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 3.60 5.54 6.92 2.78 7.57 

1947 10 69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 
948 069 883 723 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 
9^9 0:69 8:83 7 23 6 05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.7 
950 10 69 8 83 7 23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1951 10'69 8'83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1952 10:69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 
953 10 69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1954 10'69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1955 10"69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1956 10*69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1957 10'69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1958 10*69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1959 10*69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1960 10 69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1961 10*69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1962 10*69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1963 10*69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1964 10*69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1965 10 69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1966 10 69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1967 10*69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1968 10 69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1969 10 69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1970 10 69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1971 10 69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1972 10 69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1973 10 69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1974 10 69 8 83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1975 10 69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1976 10 69 8 83 7.23 6.05 4.65 9.87 8.68 12.02 12.07 16.19 13.68 13.50 130.67 

1977 12 01 9.37 8.86 7.13 7.29 9.87 8.68 12.02 12.07 16.19 13.68 13.50 130.67 

1978 12 01 9.37 8.86 7.13 7.29 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1979 10.69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1980 10 69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1981 10.69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1982 10 69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1983 10.69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1984 10.69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1985 10.69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1986 10.69 8.83 7.23 6.05 4.65 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1987 10.69 8.83 7.23 6.05 4.65 9.87 8.68 12.02 12.07 16.19 13.68 13.50 130.67 

1988 12.01 9.37 8.86 7.13 7.29 9.87 8.68 12.02 12.07 16.19 13.68 13.50 130.67 

1989 12.01 9.37 8.86 7.13 7.29 4.95 5.33 11.00 13.60 15.54 16.92 12.78 117.57 

1990 10.69 8.83 7.23 6.05 4.65 9.87 8.68 12.02 12.07 16.19 13.68 13.50 130.67 

1991 12.01 9.37 8.86 7.13 7.29 9.87 8.68 12.02 12.07 16.19 13.68 13.50 130.67 

AVG 10.90 8.91 7.49 6.22 5.06 5.79 5.90 11.17 13.34 15.65 16.36 12.90 119.82 



2-10 



Existing Level 


of Dem. 


and; Prel 


ferred A 


Lternative Minus 


No-Action; D-' 


1485 


100BU-100BH 






YEAR 


OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


TOTAL 


1922 





-2.24 


-0.86 


12.04 


-1.13 


6.16 


-5.33 





3.90 


12.30 


1.69 


1.32 


27.85 


1923 


0.53 











0.02 





-5.33 





7.26 


1.02 


1.03 


0.81 


5.34 


192A 


0.53 





-1.21 











-8.68 


-6.01 


-4.05 


-9.52 


-9.90 


-11.50 


-50.34 


1925 


-0.29 








-0.03 


-0.12 


6.16 








11.90 


12.30 


12.30 


11.90 


54.12 


1926 





-1.01 


-1.67 





8.07 





-5.33 





7.11 


1.02 


1.03 





9.22 


1927 








1.22 











-5.33 





7.12 


1.00 


1.03 


0.84 


5.88 


1928 


0.47 


0.11 














-5.33 





7.08 


1.02 


1.03 


0.84 


5.22 


1929 


0.58 


-1.20 


-2.13 











-8.68 





-0.63 


-6.54 


-5.04 


-8.24 


-31.88 


1930 


-9.28 


-7.71 


-1.46 


-0.19 


11.11 


6.16 








11.90 


12.30 


12.30 


6.05 


41.18 


1931 





-1.08 


-1.36 


-1.32 








-8.68 


-2.31 


-3.66 


-6.03 


-8.67 


-10.67 


-43.78 


1932 


-6.95 





-0.42 


11.60 














11.90 


12.30 








28.43 


1933 


-4.02 


-2.90 





-0.22 








-8.68 


-1.51 


-3.09 


-7.24 


-2.90 





-30.56 


1934 









































1935 


























11.90 


12.30 


12.30 


11.90 


48.40 


1936 


12.30 





-0.98 





-1.39 


4.15 


-5.33 





7.07 





1.53 


1.31 


18.66 


1937 


0.53 





-1.02 





-1.44 


-2.58 


-5.33 





9.10 


1.02 


1.03 


0.84 


2.15 


1938 





-1.60 


2.29 





-1.61 





-5.33 





6.99 


1.02 


1.03 


0.83 


3.62 


1939 


0.52 


0.24 


0.07 











-8.68 








-4.71 


-3.37 


-0.61 


-16.54 


1940 


-3.04 


-2.12 


-1.74 


-2.34 


-3.38 











11.90 


12.30 


12.30 


0.87 


24.75 


19A1 


0.54 








-1.48 


-2.41 


-0.36 


-5.33 





5.91 


1.02 


1.03 


0.84 


-0.24 


1942 


0.53 


0.19 


0.02 











-5.33 





6.57 


1.02 


1.03 


0.84 


4.87 


1943 


0.55 


0.19 














-5.33 





7.00 


1.02 


1.03 


0.84 


5.30 


1944 


0.57 





-0.32 











-5.33 





7.25 


1.01 


1.03 





4.21 


1945 


-0.97 


-3.14 


5.49 











-5.33 





7.18 


1.02 


1.03 


0.84 


6.14 


1946 








0.62 





0.04 


0.04 


-5.33 





7.35 


1.02 


1.03 


0.84 


5.61 


1947 


0.57 


-2.77 


-1.06 


3.83 





0.03 


-5.33 





7.31 


1.00 


1.03 





4.61 


1948 


-0.62 


-2.91 


-2.39 


-0.67 








-5.33 





11.90 


3.59 


1.09 


1.32 


5.98 


1949 


0.54 





-1.56 








1.66 


-5.33 





7.20 


1.02 


1.02 





4.55 


1950 





-1.98 


-2.48 


-2.60 


8.30 





-5.33 





7.35 


1.02 


1.03 


0.82 


6.13 


1951 


0.46 


0.12 














-5.33 





7.19 


1.02 


1.03 


0.84 


5.33 


1952 


0.52 





0.09 


-1.86 


0.68 





-5.33 





6.97 


1.02 


1.03 


0.84 


3.96 


1953 


0.58 


0.22 








0.10 


0.10 


-5.33 


-5.50 


0.20 


12.30 


1.65 


1.32 


5.64 


1954 


0.57 


0.26 


0.05 











-5.33 





7.15 


1.01 


1.03 


0.84 


5.59 


1955 


0.58 





0.19 











-5.33 





7.33 


1.02 


1.03 





4.82 


1956 





-2.25 





-3.80 


-0.28 


5.11 


-5.33 








8.14 


1.02 


0.79 


3.40 


1957 


0.46 


0.29 


0.18 


0.05 








-5.33 





6.79 


1.08 


1.08 


0.80 


5.40 


1958 


0.36 


0.18 


0.12 





-3.06 


-3.58 


-5.33 





6.26 





1.41 


1.42 


-2.22 


1959 


0.65 


0.39 


0.15 


0.03 








-5.33 


-5.50 


0.80 


12.30 


1.82 





5.31 


1960 








-2.06 








3.83 


-5.33 





7.47 


1.13 


1.06 


0.82 


6.92 


1961 





-3.10 


-0.86 





4.37 


0.07 


-5.33 


-5.50 


0.17 


12.30 


1.69 





3.81 


1962 





-3.87 


-2.47 





-2.43 


6.16 


-5.33 





10.02 





1.44 


1.19 


4.71 


1963 


0.28 


0.06 


0.06 











-5.33 





5.90 





1.50 


1.11 


3.58 


1964 


0.35 

















-5.33 





7.88 





1.43 





4.33 


1965 





-2.79 


4.57 











-5.33 





-0.85 


8.56 





1.68 


5.84 


1966 


0.54 


0.20 














-5.33 





7.53 





1.41 


1.31 


5.66 


1967 


0.56 


-1.01 


0.86 


-2.35 








-5.33 





5.43 





1.38 


1.30 


0.84 


1968 


0.56 


0.26 


0.05 











-5.33 





7.27 


1.09 





1.79 


5.70 


1969 


0.57 


-1.04 


1.08 


-1.26 








-5.33 





7.01 





2.00 


0.81 


3.84 


1970 


0.50 


0.22 


0.04 


-3.17 


-1.38 


2.77 


-5.33 





7.47 





1.49 


1.33 


3.94 


1971 


0.57 











0.05 


0.05 


-5.33 





-0.85 


8.76 


1.05 


0.88 


5.18 


1972 


0.59 


0.31 


0.10 





0.02 


0.02 


-5.33 





7.58 





1.52 


1.27 


6.08 


1973 


0.33 











-2.33 


0.68 


-5.33 





7.29 





1.51 


1.34 


3.49 


1974 


0.47 


0.10 








0.04 


0.04 


-5.33 





-0.85 


8.87 


1.05 


0.94 


5.33 


1975 


0.65 


0.29 


0.05 


0.02 








-5.33 





7.06 





1.46 


1.21 


5.41 


1976 


0.42 


0.21 


0.17 


0.14 








-8.68 


-6.01 


-1.10 


-8.39 


-3.95 


-1.95 


-29.14 


1977 


-8.00 


-7.49 


-4.59 





























-20.09 


1978 





























12.30 


12.30 


11.90 


36.50 


1979 


12.30 








-1.26 


-1.69 


6.16 


-5.33 





11.90 


1.48 


1.12 





24.68 


1980 








1.95 











-5.33 








7.71 


1.01 


0.81 


6.15 


1981 


0.54 


0.33 


0.12 





0.05 


0.05 


-5.33 





7.46 


1.25 


1.11 





5.58 


1982 








1.10 








-1.88 


-5.33 





7.74 


0.95 


1.01 


0.76 


4.35 


1983 


0.40 

















-5.33 





5.91 


1.06 


1.09 


0.89 


4.02 


1984 


0.55 


-1.75 


1.35 











-5.33 





7.87 


1.13 


1.13 


1.01 


5.96 


1985 


0.67 


0.18 








0.05 


0.05 


-5.33 





7.52 


1.17 


1.12 





5.43 


1986 





-3.57 





4.96 


-3.64 


2.04 


-5.33 





6.96 





1.53 


1.21 


4.16 


1987 


0.54 


0.50 











0.08 


-8.68 


-6.01 


-1.82 


-3.65 








-19.04 


1988 


-3.98 


-4.69 


-2.60 





11.11 





-8.68 





-0.79 


-10.31 


-5.98 


-1.10 


-27.02 


1989 

















6.15 








11.90 


12.30 


12.30 


11.90 


54.55 


1990 


6.23 








0.38 








-8.68 








-4.07 


-4.33 


-9.29 


-19.76 


1991 


-9.50 


-7.70 


-6.78 








-0.03 


-0.15 

















-24.16 



AVG 0.06 -0.93 -0.26 0.15 0.25 0.70 -5.00 -0.55 5.29 2.14 1.28 0.75 3.90 



2-11 



CGJO Delta Diversions (TAF) ,^7,, 

Existing Level of Demand, Mo-Action; 0-U85*NMFS*USfUS OCAP BO 



YEAR 
1922 
1923 


OCT 
10.69 
10.69 


NOV 
8.83 
8.83 


DEC 
7.23 
7.23 


JAN 
6.05 
6.05 


FEB 
4.65 
4.65 


HAR 
4.95 
4.95 


APR 
5.33 
5.33 


MAY 
11.00 
11.00 


JUN 
13.60 
13.60 


JUL 
15.54 
15.54 


AUG 
16.92 
16.92 


SEP 
12.78 
12.78 


TOTAL 
117.57 
117.57 


1924 


10.69 


8.83 


7.23 


6.05 


4.65 


9.87 


8.68 


12.02 


12.07 


16.19 


13.68 


13.50 


130.67 


1925 


12.01 


9.37 


8.86 


7.13 


7.29 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1926 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1927 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1928 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1929 


10.69 


8.83 


7.23 


6.05 


4.65 


9.87 


8.68 


12.02 


12.07 


16.19 


13.68 


13.50 


130.67 


1930 


12.01 


9.37 


8.86 


7.13 


7.29 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1931 


10.69 


8.83 


7.23 


6.05 


4.65 


9.87 


8.68 


12.02 


12.07 


16.19 


13.68 


13.50 


130.67 


1932 


12.01 


9.37 


8.86 


7.13 


7.29 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1933 


10.69 


8.83 


7.23 


6.05 


4.65 


9.87 


8.68 


12.02 


12.07 


16.19 


13.68 


13.50 


130.67 


193A 


12.01 


9.37 


8.86 


7.13 


7.29 


9.87 


8.68 


12.02 


12.07 


16.19 


13.68 


13.50 


130.67 


1935 


12.01 


9.37 


8.86 


7.13 


7.29 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1936 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1937 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1938 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1939 


10.69 


8.83 


7.23 


6.05 


4.65 


9.87 


8.68 


12.02 


12.07 


16.19 


13.68 


13.50 


130.67 


1940 


12.01 


9.37 


8.86 


7.13 


7.29 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1941 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1942 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1943 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1944 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1945 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1946 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1947 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1948 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1949 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1950 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1951 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1952 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1953 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1954 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1955 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1956 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1957 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1958 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1959 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1960 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1961 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1962 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1963 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1964 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1965 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1966 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1967 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1968 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1969 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1970 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1971 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1972 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1973 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1974 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1975 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1976 


10.69 


8.83 


7.23 


6.05 


4.65 


9.87 


8.68 


12.02 


12.07 


16.19 


13.68 


13.50 


130.67 


1977 


12.01 


9.37 


8.86 


7.13 


7.29 


9.87 


8.68 


12.02 


12.07 


16.19 


13.68 


13.50 


130.67 


1978 


12.01 


9.37 


8.86 


7.13 


7.29 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1979 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1980 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1981 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1982 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1983 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1984 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1985 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1986 


10.69 


8.83 


7.23 


6.05 


4.65 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 


1987 


10.69 


8.83 


7.23 


6.05 


4.65 


9.87 


8.68 


12.02 


12.07 


16.19 


13.68 


13.50 


130.67 


1988 


12.01 


9.37 


8.86 


7.13 


7.29 


9.87 


8.68 


12.02 


12.07 


16.19 


13.68 


13.50 


130.67 


1989 


12.01 


9.37 


8.86 


7.13 


7.29 


4.95 


5.33 


11.00 


13.60 


15.54 


16.92 


12.78 


117.57 



1990 10.69 8.83 7.23 6.05 4.65 9.87 8.68 12.02 12.07 16.19 13.68 13.50 130.67 

1991 12.01 9.37 8.86 7.13 7.29 9.87 8.68 12.02 12.07 16.19 13.68 13.50 130.67 

AVG 10.90 8.91 7.49 6.22 5.06 5.79 5.90 11.17 13.34 15.65 16.36 12.90 119.82 



2-12 



Difference in CCWO Delta Diversions (TAF) 

Existing Level of Demand; Preferred Alternative Minus No-Action; 



D-U85+NMFS+USFUS OCAP BO 



YEAR 


OCT 


NOV 


DEC 


JAN 


1922 





-1.88 


-0.46 


12.11 


1923 


10.77 


0.17 








1924 


0.53 











1925 


-10.56 


-5.83 


-0.09 


-0.11 


1926 


12.30 











1927 








12.30 





1928 


11.60 


0.11 








1929 


0.58 





-1.41 





1930 


-9.46 


-7.76 


-5.60 





1931 





-2.80 


-2.07 





1932 








-0.05 





1933 


11.26 











1934 


-3.86 











1935 














1936 


12.30 


11.22 








1937 


12.30 


1.88 





-1.06 


1938 


9.65 


0.19 








1939 


9.62 


0.24 


0.07 





1940 











-3.30 


1941 


12.30 


10.36 





-2.03 


1942 


0.53 


0.19 


0.02 





1943 


0.55 


0.19 








1944 


0.57 











1945 








12.30 





1946 


9.57 


0.13 


0.03 





1947 


3.82 











1948 














1949 


12.30 


7.39 


0.09 





1950 








-2.50 


-0.57 


1951 


10.21 


0.46 








1952 


9.63 


0.17 





-2.46 


1953 


9.68 


0.22 








1954 


9.64 


0.26 


0.05 





1955 


0.58 


0.22 








1956 











-4.37 


1957 


12.30 


9.93 


0.18 





1958 


0.36 


0.18 


0.12 





1959 


0.65 


0.39 


0.15 





1960 











-0.44 


1961 


0.62 


-2.31 








1962 





-3.42 








1963 


9.81 


0.06 


0.06 





1964 


3.06 


0.09 








1965 








12.30 


7.41 


1966 


3.49 


0.20 








1967 


4.25 








-2.42 


1968 


8.75 


0.26 


0.05 





1969 


0.57 





0.04 


-1.31 


1970 


9.49 


0.22 


0.04 


-2.82 


1971 


0.57 











1972 


0.59 


0.31 


0.10 





1973 


0.82 


0.05 





-0.41 


1974 


3.68 


0.10 








1975 


5.35 


0.29 


0.05 





1976 


0.42 


0.21 


0.17 





1977 





-6.18 


-7.02 


-5.45 


1978 














1979 


12.30 











1980 





11.90 


12.30 





1981 


2.52 


0.33 


0.12 





1982 








10.58 





1983 


0.40 











1984 


0.55 


-0.83 


0.43 





1985 


0.67 


0.18 








1986 





-2.83 








1987 


7.01 


0.50 








1988 





-2.05 








1989 





-6.97 


-7.40 


-0.90 


1990 


11.95 











1991 


-0.94 












FEB MAR APR 

-1.13 6.16 -5.33 

-5.33 

-8.68 

-0.12 

-5.33 



-5.33 

-8.68 



-8.68 



-8.68 





-2.19 -5.33 

-2.12 -3.32 -5.33 

-1.91 -5.33 

-8.68 

-4.20 -2.07 

-2.90 -0.53 -5.33 

-5.33 

-5.33 

-5.33 

8.88 -5.33 

-5.33 

-5.33 

-5.33 

0.06 -5.33 

-5.17 

-5.33 

1.30 -5.33 

-5.33 

-5.33 

-5.33 

-1.18 -4.96 

-5.33 

-3.05 -2.56 -5.33 

-5.33 

-5.33 

-5.33 

-2.45 -3.89 

-5.33 

-5.33 

-5.33 

-5.33 

-5.33 

-5.33 

-5.33 

1.29 -5.33 

-5.33 

-5.33 

-2.52 0.87 -5.33 

0.04 0.04 -5.33 

0.05 -5.33 

-8.68 

-4.01 -4.30 



6.16 -5.33 

-5.33 

-5.33 

-2.18 -5.33 

-5.33 

-5.33 

-5.33 

-3.69 6.15 -5.33 

-8.68 

-8.68 



-8.68 





MAY JUN JUL 

-4.03 



-6.01 -1.46 -0.02 





11.90 

7.08 



11.90 12.30 









11.90 



-5.50 -2.54 

-5.50 -6.01 









7.00 

-5.50 -5.73 

-5.50 -5.82 

-5.50 0.37 

-5.50 -5.62 



-5.50 -5.80 

11.90 

-5.50 -5.81 

-5.50 -6.03 

-5.50 -5.55 

7.16 

-5.50 -5.67 









-0.37 11.90 

-5.50 -3.63 

11.90 

-5.50 -0.85 

-5.50 -4.99 

-5.50 -0.17 

-5.50 0.51 

-5.50 -6.80 

7.27 

-5.50 -5.94 





-0.85 

-5.50 0.25 

-6.80 



-6.04 





11.90 

-4.51 

























AP BO 


167E-167D 


AUG 


SEP 


TOTAL 





11.90 


17.34 





10.00 


15.61 


-8.24 


-9.91 


-33.79 





11.90 


-4.81 








6.97 





11.90 


36.10 





2.88 


16.34 


-7.78 


-10.08 


-27.37 





11.90 


13.28 


-7.69 


-7.51 


-28.75 





11.90 


11.85 


-4.96 





-2.38 








-3.86 





11.90 


23.80 





11.90 


27.90 





11.90 


6.21 





11.90 


3.00 


-5.39 


-3.12 


-7.26 





11.90 


2.33 





9.62 


21.49 





9.33 


4.74 





2.88 


5.29 








-15.99 





11.90 


16.43 





11.90 


11.17 








-12.63 





11.90 


6.57 








3.21 





11.90 


15.56 





11.90 


5.93 





11.90 


3.68 





11.90 


5.42 





2.87 


14.65 








-15.70 





11.90 


1.39 





9.61 


26.69 





7.97 


-2.31 








-4.14 





10.23 


15.99 








-16.15 





11.90 


14.04 





11.90 


10.15 








-12.67 





11.90 


20.61 





11.30 


4.67 





11.90 


-3.90 





2.87 


13.87 





11.90 


-5.57 





10.17 


13.06 





9.86 


5.10 





10.62 


5.44 





11.90 


0.13 





11.90 


3.63 





9.61 


10.02 


-7.01 


-0.97 


-21.90 








-26.96 





11.90 


11.90 








25.03 





11.90 


26.26 








-2.36 





10.62 


13.69 


7.99 


0.89 


3.95 





10.98 


5.80 








-4.48 





11.90 


6.20 


-4.70 





-5.87 


-6.30 





-17.03 





11.90 


-3.37 


-6.80 





-3.53 








-0.94 



AVG 



3.51 



0.22 



0.50 



-0.12 -0.28 



0.09 



-4.92 



-1.58 



0.18 



0.18 



-0.73 



6.51 



3.55 



2-13 



Net Delta Outflow (TAF) 

Existing Level of Demand, No-Action; D-U85 



YEAR 


OCT 


NOV 


DEC 


JAN 


FEB 


HAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


TOTAL 


1922 


277 


299 


485 


698 


2111 


1734 


800 


2791 


1977 


489 


429 


324 


12412 


1923 


317 


674 


1712 


1716 


666 


362 


968 


663 


565 


433 


434 


342 


8853 


1924 


277 


287 


351 


392 


352 


277 


268 


277 


229 


237 


194 


160 


3300 


1925 


215 


235 


298 


281 


2560 


738 


841 


797 


637 


532 


422 


240 


7796 


1926 


277 


268 


277 


520 


1693 


390 


803 


466 


364 


393 


400 


241 


6093 


1927 


277 


754 


470 


1467 


6839 


2376 


2562 


1218 


833 


615 


484 


309 


18204 


1928 


277 


732 


438 


968 


1000 


5879 


1134 


466 


451 


533 


490 


296 


12663 


1929 


277 


268 


360 


356 


405 


316 


280 


279 


231 


362 


226 


183 


3543 


1930 


215 


208 


365 


914 


443 


1301 


451 


466 


407 


436 


423 


241 


5870 


1931 


277 


268 


277 


359 


280 


277 


268 


277 


229 


237 


194 


166 


3109 


1932 


215 


208 


511 


557 


790 


362 


451 


466 


407 


411 


259 


220 


4857 


1933 


277 


281 


277 


365 


273 


291 


268 


277 


229 


237 


194 


175 


3144 


1934 


215 


208 


336 


589 


455 


281 


268 


277 


229 


237 


194 


180 


3469 


1935 


215 


24 7 


215 


1452 


666 


1208 


2235 


909 


637 


525 


488 


355 


9153 


1936 


277 


280 


366 


1536 


4335 


1521 


703 


797 


637 


523 


487 


332 


11793 


1937 


277 


343 


277 


390 


2083 


2883 


761 


725 


565 


400 


401 


231 


9336 


1938 


277 


1205 


3578 


1704 


7906 


10222 


3858 


4002 


2503 


615 


468 


388 


36726 


1939 


979 


468 


358 


406 


433 


398 


399 


299 


231 


393 


400 


215 


4979 


1940 


277 


363 


277 


1338 


2596 


6261 


3447 


797 


637 


528 


518 


336 


17375 


1941 


277 


332 


2303 


6008 


6599 


5845 


4632 


2386 


940 


615 


469 


312 


30718 


1942 


641 


618 


3567 


4881 


7773 


1345 


2812 


2074 


1351 


615 


450 


245 


26372 


1943 


880 


698 


1360 


4820 


3094 


4934 


1403 


826 


833 


615 


465 


312 


20239 


1944 


277 


268 


367 


382 


1204 


754 


516 


466 


364 


390 


356 


229 


5572 


1945 


277 


368 


535 


375 


2360 


1119 


451 


663 


565 


427 


433 


284 


7857 


1946 


277 


513 


3924 


2798 


796 


958 


451 


797 


637 


534 


476 


273 


12433 


1947 


277 


271 


407 


375 


632 


650 


451 


466 


364 


393 


373 


246 


4905 


1948 


277 


268 


277 


396 


349 


738 


730 


1252 


785 


531 


491 


338 


6431 


1949 


277 


282 


361 


396 


307 


2642 


462 


466 


364 


390 


350 


265 


6563 


1950 


277 


268 


277 


808 


1497 


747 


577 


663 


565 


437 


437 


314 


6R67 


1951 


326 


2114 


5882 


4008 


3606 


1706 


597 


865 


451 


532 


521 


341 


20949 


1952 


277 


368 


2599 


5519 


4286 


3805 


3672 


4046 


2512 


615 


427 


523 


28649 


1953 


1151 


497 


2429 


5946 


1258 


1014 


714 


1327 


1236 


615 


517 


322 


17025 


1954 


369 


715 


331 


1328 


3027 


2655 


2084 


797 


637 


533 


490 


343 


13308 


1955 


277 


356 


995 


929 


317 


362 


502 


466 


364 


390 


372 


268 


5598 


1956 


277 


290 


4442 


9991 


5080 


1950 


811 


2473 


1212 


615 


481 


338 


27960 


1957 


943 


398 


277 


457 


1758 


2435 


459 


785 


565 


436 


437 


342 


9290 


1958 


598 


562 


1048 


1968 


8642 


7755 


6225 


2576 


2348 


615 


486 


501 


33325 


1959 


984 


407 


291 


1844 


2800 


695 


457 


466 


364 


393 


407 


306 


9414 


1960 


277 


367 


284 


344 


1164 


738 


533 


466 


408 


439 


409 


264 


5692 


1961 


277 


300 


377 


360 


1061 


576 


451 


466 


364 


393 


358 


252 


5236 


1962 


277 


268 


377 


301 


2660 


948 


483 


663 


565 


444 


404 


275 


7665 


1963 


1453 


628 


1137 


550 


4107 


1652 


5052 


1543 


833 


615 


519 


324 


18411 


1964 


355 


1155 


331 


1012 


328 


369 


499 


466 


364 


394 


403 


244 


5921 


1965 


277 


337 


3824 


7100 


1564 


869 


2597 


853 


833 


615 


475 


310 


19653 


1966 


418 


1146 


564 


1437 


1122 


1264 


451 


466 


408 


439 


439 


335 


8488 


1967 


277 


364 


2257 


2984 


3045 


3420 


2848 


3031 


2805 


849 


404 


567 


22852 


1968 


1194 


515 


430 


1343 


3633 


1993 


451 


466 


408 


439 


439 


289 


11601 


1969 


277 


351 


768 


7048 


7501 


3391 


2791 


3894 


1867 


615 


475 


518 


29495 


1970 


1051 


665 


3117 


11972 


4949 


2215 


595 


466 


451 


532 


521 


315 


26848 


1971 


277 


819 


3766 


2769 


1066 


2771 


731 


1638 


980 


615 


516 


322 


16270 


1972 


395 


372 


688 


592 


888 


1568 


458 


466 


408 


438 


439 


336 


7048 


1973 


299 


682 


1118 


4585 


5114 


3518 


595 


809 


833 


615 


479 


317 


18964 


1974 


290 


3301 


4109 


7831 


2337 


6497 


3944 


1277 


933 


615 


489 


445 


32069 


1975 


682 


589 


588 


453 


3722 


5345 


932 


1808 


1252 


522 


482 


346 


16721 


1976 


782 


612 


415 


349 


490 


373 


318 


277 


231 


370 


348 


195 


4760 


1977 


215 


344 


293 


289 


250 


277 


268 


277 


229 


237 


194 


149 


3022 


1978 


215 


208 


375 


3905 


3241 


3894 


2268 


1259 


833 


615 


490 


313 


17616 


1979 


303 


305 


277 


1008 


2263 


1734 


584 


617 


364 


390 


400 


332 


8577 


1980 


281 


615 


736 


6461 


7465 


4273 


983 


877 


833 


615 


493 


255 


23888 


1981 


620 


368 


403 


787 


987 


1721 


451 


466 


364 


393 


406 


277 


7243 


1982 


277 


1403 


5212 


4972 


5488 


5124 


8433 


3249 


1357 


615 


451 


805 


37387 


1983 


IfWi 


2560 


5353 


6347 


10411 


16055 


6492 


5168 


4566 


1924 


569 


1365 


62696 


1984 


2030 


4515 


9512 


5198 


2686 


2386 


674 


627 


451 


520 


506 


326 


29430 


1985 


567 


1638 


1255 


422 


678 


773 


451 


466 


364 


393 


406 


293 


7706 


1986 


277 


311 


463 


732 


12180 


9441 


1842 


803 


451 


466 


473 


299 


27739 


1987 


338 


268 


285 


394 


540 


1161 


399 


299 


231 


391 


354 


232 


4891 


1988 


277 


268 


405 


1100 


337 


277 


298 


277 


231 


392 


287 


210 


4359 


1989 


215 


241 


249 


331 


270 


2022 


703 


466 


407 


447 


444 


367 


6161 


1990 


284 


268 


337 


483 


336 


304 


357 


292 


231 


369 


194 


190 


3645 


1991 


215 


216 


241 


277 


257 


1149 


327 


277 


230 


354 


203 


236 


3982 



AVG 450 617 1321 2185 2620 2390 1386 1065 765 499 414 319 14031 



2-14 



Existing 


Level 


of Demand, 


; Pref 


erred Alternative 


Minus 


No-Action; 


D-1485 




100BU-100BH 






YEAR 


OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL AUG 


SEP 


TOTAL 


1922 





-2 


1 


-10 


2 


-7 


5 


2 


-4 


9 





-4 


1923 


-6 








-4 








-10 








1 





-19 


1924 








-1 























-6 


-7 


1925 














1 





-2 








8 -2 


7 


12 


1926 














-8 





2 














-6 


1927 








-1 


-21 








6 











1 


-15 


1928 





-12 














6 














-6 


1929 








-1 




















-3 -4 





-8 


1930 














-11 


-2 











5 -12 


3 


-17 


1931 






































1932 











-5 


39 














-3 





31 


1933 





-3 





1 























-2 


1934 








2 





22 




















24 


1935 





























7 4 


1 


12 


1936 


5 


-1 


-1 


-4 


-47 


-10 


5 











-2 


-55 


1937 





-1 











3 


5 








1 





8 


1938 





-11 


-2 


1 


1 





5 





-7 


1 


-3 


-15 


1939 


-1 














1 











-1 





-1 


1940 











4 


25 


2 











7 4 





42 


1941 








-45 


1 


3 


1 


6 





-6 





1 


-39 


1942 


-1 


-1 


-3 











6 





-6 





-1 


-6 


1943 


-1 


-1 








-2 





5 














1 


1944 














-1 





-3 














-4 


1945 





3 


-21 





8 


1 











1 





-8 


1946 





-5 


-1 


-1 




















1 


-6 


1947 





-1 


-2 


2 

















-1 





-2 


1948 




















5 


-1 


-12 


-2 





-10 


1949 





-1 


1 











-3 








-1 





-4 


1950 











3 


-9 





5 








1 


-2 


-2 


1951 





-2 


-3 








2 


5 








1 





3 


1952 





-9 


-4 


2 








5 





-7 


2 


-1 


-12 


1953 


-4 

















5 


6 











7 


1954 


-1 


-8 





-1 





-6 


5 














-11 


1955 





-3 


-1 


-2 


-1 





-1 








1 





-7 


1956 





-8 


2 


4 





-5 


10 








-1 


-1 


1 


1957 


-3 


-1 











-6 


-4 


7 





1 1 





-5 


1958 


-6 


-3 





1 


3 


4 


5 





-6 


1 


-1 


-2 


1959 


-1 


-1 








-2 





-3 








4 -1 





-4 


1960 








-1 











-2 








1 





-2 


1961 





-1 








-5 














3 





-3 


1962 








■ 





2 


-6 


-4 











1 


-7 


1963 


-6 








-1 


1 





5 








1 








1964 





-12 














-3 








1 





-14 


1965 





-1 


-2 











5 














2 


1966 


-7 


-4 


-1 























1 


-11 


1967 








-5 


3 


-1 





6 





-5 


1 


-4 


-5 


1968 






































1969 








-1 


-3 








5 





-7 





-1 


-7 


1970 


-1 


-1 





3 


-1 


-3 











1 





-2 


1971 





-6 














6 





1 








1 


1972 


-1 


-3 


-9 











-3 








1 





-15 


1973 





-3 


-1 


2 


2 


-1 


5 








1 


1 


6 


1974 


1 


-11 














6 





1 





-1 


-4 


1975 





-9 














6 





-7 





-1 


-11 


1976 


-1 














-3 


-6 








-4 -2 


-1 


-17 


1977 








-3 


























-3 


1978 











45 





3 











4 


5 


57 


1979 


-10 


-4 





1 


-43 


-6 


5 








1 





-56 


1980 


-4 


-4 


-1 








-6 


6 











1 


-8 


1981 


-6 


-2 








-1 


-1 











1 





-9 


1982 








-1 





6 


2 


5 





-7 


1 


-4 


2 


1983 


-1 

















5 





-5 


-1 -1 


-1 


-4 


1984 


-1 


1 


-1 











5 








1 1 


-1 


5 


1985 





-4 





■5 


-3 




















-12 


1986 





-2 





-4 


4 


■2 


6 











1 


3 


1987 


-1 





2 


1 





-6 











-1 -1 





-6 


1988 








1 


-1 


5 





-3 





-1 








1 


1989 














1 


-6 











6 2 


1 


4 


1990 


-1 


























-2 


9 


6 


1991 





-8 


-7 





-1 














2 





-14 



AVG 



-0 



2-15 



Net Delta OutfloM (TAf) 

Existing Level of Demand, No-Action; D-K85*NHFS*USFWS OCAP BO ''"^ 



YEAR 


OCT 


NOV 


DEC 


JAN 


FES 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


TOTAL 


1922 


277 


268 


485 


707 


2246 


1793 


1161 


2955 


2051 


473 


441 


369 


13226 


1923 


412 


681 


1712 


1621 


718 


594 


1294 


870 


642 


401 


384 


378 


9707 


1924 


307 


268 


331 


389 


704 


345 


436 


277 


269 


257 


239 


155 


3978 


1925 


215 


234 


306 


285 


2702 


1027 


1268 


1044 


714 


474 


438 


376 


9083 


1926 


277 


268 


277 


589 


1848 


726 


1236 


466 


404 


286 


362 


384 


7122 


1927 


296 


754 


724 


1789 


6620 


2352 


2785 


1430 


833 


615 


475 


371 


19044 


1928 


355 


735 


439 


1161 


1148 


5691 


1432 


693 


491 


414 


438 


378 


13377 


1929 


303 


268 


292 


405 


721 


585 


439 


308 


269 


237 


225 


226 


4278 


1930 


215 


208 


421 


1209 


822 


1616 


637 


466 


447 


330 


397 


230 


6998 


1931 


277 


268 


277 


428 


510 


350 


438 


304 


269 


237 


194 


205 


3757 


1932 


215 


208 


588 


641 


731 


499 


503 


505 


447 


330 


384 


308 


5358 


1933 


277 


268 


277 


480 


597 


569 


436 


327 


269 


264 


366 


239 


4369 


1934 


215 


208 


367 


677 


717 


593 


438 


282 


269 


237 


264 


230 


4498 


1935 


215 


261 


242 


1429 


666 


1334 


2575 


1122 


714 


474 


440 


374 


9847 


1936 


359 


268 


282 


1702 


4473 


1528 


1064 


800 


714 


474 


441 


375 


12479 


1937 


345 


268 


277 


412 


2172 


2968 


1121 


937 


642 


400 


385 


372 


10300 


1938 


337 


1264 


3578 


1547 


7533 


10084 


3886 


4095 


2577 


615 


481 


390 


36387 


1939 


975 


447 


320 


408 


562 


628 


437 


299 


269 


258 


365 


382 


5348 


1940 


277 


268 


284 


1396 


3169 


6339 


3661 


946 


714 


474 


473 


373 


18374 


1941 


334 


281 


2538 


5928 


6599 


5845 


4850 


2598 


1014 


615 


477 


350 


31428 


1942 


695 


625 


3396 


4881 


7773 


1445 


2975 


2280 


1426 


615 


479 


322 


26911 


1943 


944 


702 


1252 


4820 


3077 


4770 


1657 


1039 


833 


615 


475 


373 


20557 


1944 


296 


301 


311 


446 


1239 


1111 


454 


466 


404 


286 


363 


372 


6048 


1945 


277 


383 


609 


432 


2611 


1235 


598 


715 


642 


401 


386 


368 


8658 


1946 


277 


784 


3924 


2721 


952 


1130 


648 


797 


714 


474 


439 


370 


13229 


1947 


290 


268 


433 


331 


868 


1059 


619 


466 


404 


286 


360 


369 


5751 


1948 


277 


268 


277 


494 


470 


740 


1536 


1764 


859 


474 


435 


383 


7977 


1949 


361 


385 


313 


336 


573 


2652 


611 


499 


404 


286 


363 


336 


7119 


1950 


277 


268 


277 


1110 


1590 


1130 


938 


817 


642 


401 


382 


386 


8218 


1951 


365 


2723 


6089 


4008 


3655 


1825 


855 


1028 


491 


467 


470 


378 


22353 


1952 


343 


589 


2549 


5482 


4286 


3829 


3791 


4138 


2586 


713 


478 


523 


29305 


1953 


1026 


497 


2429 


5946 


1201 


1127 


952 


1538 


1318 


615 


465 


378 


17491 


1954 


478 


744 


364 


1564 


3045 


2643 


2342 


845 


714 


474 


430 


381 


14023 


1955 


357 


455 


1207 


1049 


597 


557 


477 


481 


404 


286 


358 


386 


6614 


1956 


277 


273 


5120 


9991 


5151 


2088 


1067 


2685 


1286 


615 


466 


393 


29411 


1957 


1013 


420 


310 


385 


1802 


2425 


540 


1214 


642 


401 


372 


385 


9910 


1958 


847 


715 


1207 


1915 


8642 


7580 


6319 


2788 


2422 


615 


468 


501 


34019 


1959 


1014 


471 


310 


1837 


2759 


961 


506 


499 


404 


286 


355 


396 


9797 


1960 


310 


268 


280 


385 


1397 


1370 


451 


532 


448 


330 


379 


382 


6532 


1961 


277 


280 


642 


402 


1640 


970 


451 


466 


404 


286 


358 


331 


6506 


1962 


277 


268 


500 


307 


3202 


1336 


564 


663 


642 


400 


372 


340 


8871 


1963 


1659 


628 


1405 


1133 


4112 


1698 


5144 


1756 


833 


615 


461 


383 


19828 


1964 


490 


1394 


368 


1191 


640 


533 


469 


466 


404 


286 


361 


384 


6986 


1965 


277 


326 


4585 


7100 


1670 


1143 


2801 


1066 


833 


615 


474 


372 


21261 


1966 


656 


1167 


586 


1437 


1228 


1265 


650 


624 


448 


330 


377 


385 


9153 


1967 


335 


542 


2346 


2874 


3110 


3405 


2975 


3124 


2879 


1037 


476 


510 


23613 


1968 


1051 


515 


430 


1460 


3392 


1963 


506 


630 


448 


330 


388 


377 


11491 


1969 


311 


304 


1257 


7153 


7501 


3339 


2937 


3987 


1942 


615 


473 


518 


30337 


1970 


1014 


665 


3117 


11972 


4686 


2123 


595 


699 


491 


467 


461 


380 


26669 


1971 


347 


1204 


3785 


2708 


1197 


2781 


1073 


1850 


1054 


615 


464 


378 


17456 


1972 


535 


426 


738 


607 


1125 


1658 


559 


620 


448 


330 


371 


378 


7796 


1973 


406 


1066 


1427 


4455 


5114 


3504 


862 


1022 


833 


615 


461 


380 


20144 


1974 


356 


3154 


4109 


7831 


2337 


6486 


4074 


1489 


1007 


615 


465 


445 


32368 


1975 


839 


592 


588 


508 


3558 


5170 


1187 


2021 


1327 


474 


435 


436 


17134 


1976 


960 


746 


421 


389 


863 


721 


440 


277 


269 


251 


366 


303 


6006 


1977 


215 


208 


234 


277 


250 


277 


440 


327 


269 


237 


231 


149 


3115 


1978 


215 


208 


342 


4574 


2975 


3883 


2388 


1472 


833 


615 


471 


369 


18345 


1979 


318 


305 


277 


1066 


2091 


1773 


861 


829 


404 


286 


362 


381 


8953 


1980 


446 


751 


736 


6416 


7465 


4187 


1124 


1041 


833 


615 


474 


328 


24416 


1981 


700 


383 


403 


951 


1184 


1492 


620 


466 


404 


286 


361 


383 


7633 


1982 


315 


1833 


5021 


4980 


5527 


5174 


8677 


3341 


1431 


696 


479 


740 


38215 


1983 


1867 


2560 


5353 


6333 


10139 


15957 


6478 


5261 


4640 


2112 


569 


1365 


62634 


1984 


2030 


4424 


9507 


5024 


2632 


2360 


909 


839 


491 


467 


474 


503 


29661 


1985 


636 


1747 


1255 


425 


865 


926 


527 


466 


404 


286 


363 


382 


8281 


1986 


295 


268 


478 


1036 


12453 


9484 


2130 


1052 


525 


467 


479 


344 


29012 


1987 


338 


276 


277 


370 


855 


1409 


436 


299 


269 


257 


364 


308 


5458 


1988 


277 


268 


446 


1313 


505 


277 


446 


292 


269 


257 


364 


296 


5010 


1989 


215 


208 


231 


315 


308 


2666 


1118 


466 


447 


330 


386 


342 


7032 


1990 


277 


268 


277 


606 


665 


546 


440 


333 


269 


256 


364 


282 


4583 


1991 


215 


208 


215 


277 


298 


1444 


625 


315 


269 


323 


361 


283 


4834 



AVG 491 657 1372 2240 2722 2501 1571 1184 815 455 406 380 14795 



2-16 



Difference in Net Delta Outflow (TAF) 

Existing Level of Demand; Preferred Alternative Minus No-Action; 0-U85+NMFS+USFUS OCAP BO 



167E-167D 



YEAR 
1922 
1923 
192A 
1925 
1926 
1927 
1928 
1929 
1930 
1931 
1932 
1933 
1934 
1935 
1936 
1937 
1938 
1939 
1940 
1941 
1942 
1943 
1944 
1945 
1946 
1947 
1948 
1949 
1950 
1951 
1952 
1953 
1954 
1955 
1956 
1957 
1958 
1959 
1960 
1961 
1962 
1963 
1964 
1965 
1966 
1967 
1968 
1969 
1970 
1971 
1972 
1973 
1974 
1975 
1976 
1977 
1978 
1979 
1980 
1981 
1982 
1983 
1984 
1985 
1986 
1987 
1988 
1989 
1990 
1991 



OCT 

-25 





-4 








-1 

-1 


-8 



-1 

-1 



4 





-3 

-10 

-10 





-12 



-1 







-19 

-3 



-17 

1 

-8 


-9 

-2 



-10 



-6 




2 
2 
1 


-1 

-1 


-7 







NOV 



-2 



-4 










-32 
-1 

4 





-10 



-19 


-35 
-3 


-1 



-1 




-1 





-1 



-13 



1 

-1 

-5 


-2 
-18 





-12 


-1 

1 



-1 







DEC 
1 




-13 


23 




13 









-2 



-39 

-12 

-11 



-12 



-7 





-1 




-1 






-4 
2 



-32 
-1 
-4 





-13 
-1 



-6 



-12 


-11 












JAN 
-11 





-1 








-22 










-9 



1 


-9 

-13 

5 

-13 





-2 


-7 


-2 


-2 
3 



-1 





36 
4 


7 




1 









FEB 

1 




1 

-7 

1 









3 

-12 





-11 

-11 

13 

2 
3 




-9 






17 

-1 



2 

3 



2 





-1 



-2 
-1 

2 




8 
-21 

1 




6 








MAR 
-7 
-2 






-1 









5 

-2 

4 
1 








-1 

-42 






3 












13 



-1 





8 

-6 



-14 

2 

-1 



-6 
3 

9 





APR 



46 





18 







7 

2 
3 







-10 



7 





4 




3 










3 




12 


7 
6 











MAY 
1 















3 













4 














3 

4 

























JUN 









































































JUL 











21 




1 














1 













































AUG 


-14 




-16 



-5 
-2 

















































-8 











SEP 

t, 

3 




4 

1 
1 

-3 


5 
-15 

4 
4 
4 

-11 
-1 

3 
2 
3 

1 





4 

3 
4 

-12 
4 



-12 
3 

-8 




5 

3 
4 

-12 


-12 
3 
3 
3 
4 

-12 

-10 

-10 






-11 
-1 

-11 

3 








TOTAL 

-11 

-24 

-14 

45 

-7 

-9 

-8 

-15 

38 



8 

-11 

11 

4 

-30 

-2 

-22 

-12 

11 

-26 

-10 

-11 



-21 

-19 

-3 

-6 

-20 

5 

-56 

-18 

-6 

-23 

-2 

-5 

-9 

-12 

-1 



-5 

4 

-13 

-3 

-37 

-14 

-28 

-8 

-9 

7 

-5 

-10 

-9 

-27 

-16 

-10 

-6 

52 

-11 

-22 

-11 

-6 

-4 

-11 

-1 

4 

-5 



9 







AVG 



-2 



-2 



-1 



-0 



-1 



-1 



-1 



2-17 



QWEST (CfS) 

Existing Level of Demand, No-Action; 0-K85 



100BH 



YEAR 


OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


1922 


-496 


-1568 


-924 


664 


7708 


3040 


1241 


6220 


5125 


■1720 


-2331 


-2223 


1923 


-2067 


37 


3500 


3216 


2864 


-1513 


1972 


2698 


2310 


■2694 


-3727 


-2806 


1924 


-1041 


-1725 


-2578 


-2594 


-2708 


-575 


-722 


359 


-11 


397 


764 


265 


1925 


-212 


-931 


-1336 


-716 


1510 


-1103 


577 


3281 


1658 


■2311 


-2375 


-813 


1926 


-893 


-295 


■493 


-2113 


-1364 


-2898 


-650 


1081 


96 


■2986 


-4046 


-832 


1927 


-700 


-849 


-3151 


-3373 


9309 


692 


1917 


5175 


3199 


-1739 


-2949 


-1878 


1928 


-1050 


-258 


-2018 


-4137 


2254 


9259 


-2900 


1542 


559 


-2312 


-3613 


-1683 


1929 


-891 


-1261 


■2467 


-1661 


-1917 


-1415 


130 


503 


-351 


-2235 


-348 


-73 


1930 


432 


-625 


-2477 


-4757 


-2028 


-3557 


-728 


732 


377 


-2751 


-3613 


■797 


1931 


-500 


-945 


-1172 


-1621 


-1162 


1791 


962 


1085 


413 


1568 


785 


151 


1932 


1291 


929 


-1180 


■1479 


4974 


104 


-342 


1016 


217 


-2465 


■268 


-508 


1933 


669 


-1203 


-1384 


■1667 


-1218 


-1162 


1651 


1420 


576 


473 


649 


21 


1934 


454 


1041 


-1730 


■1540 


-248 


-1149 


1002 


763 


516 


1444 


479 


-24 


1935 


897 


-671 


-250 


471 


5091 


3341 


1962 


3712 


1120 


-2210 


■3474 


-3413 


1936 


-1328 


-1601 


-2780 


-1279 


13729 


-2338 


-127 


3279 


2318 


-2167 


-3496 


-2428 


1937 


-925 


-2463 


-682 


-1360 


8505 


12207 


582 


4186 


2466 


-1740 


-2596 


-694 


1938 


-811 


-4297 


754 


208 


31817 


36739 


8994 


18132 


14486 


2220 


-1701 


-1221 


1939 


4376 


-1694 


-1998 


-1132 


968 


-278 


-1056 


439 


-531 


-2986 


-3988 


-650 


1940 


-251 


-2809 


-1407 


-1626 


2198 


5438 


■1443 


3368 


2423 


-2245 


-3370 


-2575 


1941 


-110 


-2025 


-1379 


7437 


14324 


15487 


10310 


3258 


4839 


-13 


-1987 


-1930 


1942 


959 


-1033 


3593 


10555 


13619 


4157 


3501 


2411 


1374 


■1106 


-2086 


-862 


1943 


4593 


214 


-2488 


10913 


9359 


19863 


■211 


3662 


2686 


■1681 


-2390 


-1917 


1944 


-664 


-605 


-2550 


-1948 


4603 


-480 


■1946 


908 


263 


■2976 


-2677 


-700 


1945 


-879 


-1622 


-941 


■1419 


5939 


3778 


■476 


2652 


2092 


-2567 


-3639 


-1449 


1946 


-561 


-894 


5743 


1134 


1771 


2694 


-13 


2987 


1356 


-2272 


-3267 


-1147 


1947 


-1074 


-1374 


-1825 


■2165 


4 


-1418 


-857 


971 


171 


-2971 


-3402 


-939 


1948 


-1280 


-1161 


-935 


-2776 


-2655 


-625 


-741 


•606 


1549 


-2502 


-3798 


-2715 


1949 


-1339 


-1631 


-2678 


-2704 


-1592 


665 


■1205 


767 


159 


-2985 


-2453 


-1113 


1950 


-878 


-806 


-811 


-4233 


-1673 


-718 


■1140 


2468 


1723 


-2761 


-3861 


-2052 


1951 


-2177 


3810 


21703 


11514 


8103 


819 


55 


3525 


1155 


-2312 


-3498 


-2915 


1952 


-911 


-2281 


1438 


14741 


8722 


9703 


8337 


14105 


10154 


731 


-1382 


-740 


1953 


5042 


-1660 


-25 


5955 


1024 


3145 


588 


-43 


-1371 


-1972 


-3593 


-2353 


1954 


-3100 


-736 


-2537 


-4360 


-319 


195 


■892 


2734 


1693 


-2420 


-3752 


-3050 


1955 


-1045 


-2709 


505 


-2653 


-1661 


-1748 


■1603 


672 


135 


-3050 


-3423 


-1184 


1956 


-795 


-1533 


3318 


29549 


12318 


-1911 


1078 


4859 


7304 


-817 


-2480 


-2744 


1957 


4675 


-2373 


-745 


-1587 


-902 


161 


-966 


2735 


1752 


-2870 


-4010 


-2962 


1958 


-2361 


-1593 


-4580 


-717 


10925 


21306 


26581 


6364 


9734 


13 


-2377 


-2159 


1959 


4901 


-2069 


-1640 


-1600 


4330 


635 


-1115 


980 


-9 


-3113 


-4178 


-1730 


1960 


-721 


-2941 


-1504 


-1416 


-3336 


-990 


-2398 


354 


340 


-2848 


-3658 


-1175 


1961 


-582 


-1527 


-3232 


■1524 


-4912 


-2117 


-52 


757 


100 


-3088 


-2848 


-1032 


1962 


-303 


-723 


-2938 


■999 


3645 


-457 


-1471 


2279 


786 


-2955 


-3377 


-1315 


1963 


-21 


-1793 


-4971 


■1417 


7208 


-754 


5879 


-82 


2006 


-2072 


-3588 


-2295 


1964 


-2647 


-4028 


-2609 


■3916 


-2069 


-2302 


-1821 


1074 


242 


-3077 


-4228 


-933 


1965 


-725 


-2241 


6995 


15880 


-128 


1041 


1114 


3417 


2864 


-1662 


-2792 


-1997 


1966 


510 


-1883 


306 


-931 


3353 


-1875 


■921 


1277 


233 


-2916 


-3990 


-2669 


1967 


-678 


-2692 


131 


4237 


2648 


5475 


10285 


10216 


13144 


5638 


-872 


-837 


1968 


5510 


-1610 


-2001 


-2898 


7741 


1040 


■770 


1234 


225 


-2941 


-3824 


-1639 


1969 


-919 


-2534 


-833 


15471 


32382 


9182 


9636 


25583 


10925 


3629 


-2015 


-1770 


1970 


4482 


344 


1138 


25057 


11927 


3795 


51 


1244 


1053 


-2504 


-3623 


-2157 


1971 


-795 


540 


4576 


-82 


-3613 


-157 


■90 


896 


3009 


-2031 


-3601 


■2329 


1972 


-3114 


-2743 


-799 


■1249 


893 


-1465 


-1102 


1049 


249 


-2991 


-4106 


-2667 


1973 


-1576 


-355 


-4626 


5206 


13273 


7617 


-134 


2885 


2640 


-2094 


-2950 


-2118 


1974 


-1443 


1832 


5487 


11707 


1285 


11334 


692 


5684 


3296 


-639 


-2588 


-3326 


1975 


164 


-193 


-689 


-1901 


11936 


12669 


2237 


2273 


614 


-2506 


-3588 


-3098 


1976 


295 


-63 


■1873 


-1679 


-2396 


-1330 


-1545 


-66 


■600 


-2448 


-2204 


-205 


1977 


-23 


-2220 


■1648 


-960 


-970 


2117 


1753 


1301 


1421 


1358 


641 


913 


1978 


1953 


257 


■2728 


4985 


9244 


7817 


5600 


9039 


6192 


-180 


-2374 


-1944 


1979 


-18^4 


-2040 


■289 


-2196 


7285 


2854 


-100 


1605 


657 


-3087 


-3929 


-2482 


1980 


-1290 


-377 


■736 


20408 


31151 


23177 


6163 


5911 


5008 


273 


-2362 


-980 


1981 


2150 


-1306 


■1696 


-3661 


-3534 


990 


-852 


1335 


47 


-3082 


-4053 


-1261 


1982 


-369 


-3965 


3070 


12724 


17214 


21716 


37369 


22129 


9694 


2173 


-1498 


1606 


1983 


6163 


8460 


26299 


31597 


56872 


72713 


39496 


33107 


32958 


17864 


910 


8529 


1984 


10594 


19236 


36349 


30767 


15045 


8211 


2635 


3146 


1742 


-2216 


-3123 


-2356 


1985 


-1409 


-1324 


-1533 


-1288 


885 


2373 


-437 


1485 


145 


-3028 


-4008 


-1577 


1986 


-352 


-1700 


-1952 


■177 


38941 


38041 


17757 


7166 


2350 


-728 


-2047 


-1582 


1987 


159 


465 


-1147 


■2619 


-1491 


-4001 


-676 


416 


■529 


-2966 


-2604 


-730 


1988 


530 


-767 


-2669 


-4464 


-2263 


-932 


-1205 


165 


-606 


-3178 


-1233 


-526 


1989 


-555 


-916 


-919 


■1379 


-1138 


-2035 


-1032 


1285 


225 


-2929 


-4017 


-3713 


1990 


-1416 


-439 


■2006 


■2457 


-2273 


-1358 


801 


395 


-611 


-2392 


483 


-205 


1991 


623 


-572 


■860 


-495 


-1062 


-3968 


-1617 


-264 


-457 


-2184 


-153 


-697 



AVG 



176 



-758 



421 



2564 



5861 



4868 



2536 



3753 



2615 -1370 



-2581 



■1363 



2-18 



Existing 


Level 


of Demand 


; Prefi 


erred Alternative 


Minus 


No-Action; 


D-1485 






100BW-100BH 




YEAR 


OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


1922 





19 


14 


-188 


22 


-100 


89 


4 


-65 


-98 


-16 


-14 


1923 


140 








-9 





-87 


-76 





-86 


-10 


-11 


-9 


1924 


-6 





11 








-2 


101 


64 


43 


106 


114 


83 


1925 


4 











4 


-71 


-8 





-141 


-106 


-97 


-71 


1926 





12 


19 





-145 


-9 


70 





-85 


-10 


-13 





1927 








-20 


-45 


4 





90 





-85 


-12 


-10 


-8 


1928 


-12 


-58 











-1 


100 





-84 


-9 


-11 


-7 


1929 


-7 


16 


20 











103 





8 


58 


36 





1930 


201 


92 





3 


-200 


-91 


18 





-142 


-115 


-197 


-36 


1931 





-5 


16 











-1 


2 


3 


2 








1932 





-2 


7 


-77 


713 





14 


21 


-141 


-124 








1933 


12 


78 


7 


1 











10 





81 


1 


-1 


1934 





6 


-39 





400 








1 


1 


1 








1935 


1 























-142 


-106 


-124 


-42 


1936 


-89 


8 


10 


-8 


-91 


-79 


90 





-84 





-14 


36 


1937 


-7 


19 


17 





24 


42 


90 





-109 


-11 


-10 


-2 


1938 





-1 


-37 


3 


29 


-15 


90 





-118 





-19 


-23 


1939 


-13 


-6 


-1 








1 


105 








47 


41 


14 


1940 


35 


26 


21 


41 


113 


4 








-142 


-106 


-123 


7 


1941 


-6 


3 


-98 


23 


44 


5 


92 





-99 


-12 


-10 


-8 


1942 


-12 


-3 


-7 





J 





89 





-110 


-12 


-9 


8 


1943 


-13 


-3 








-32 





89 





-84 


-11 


-10 


-8 


1944 





-7 


2 





-3 





53 





-86 


-11 


-9 





1945 


11 


52 


-163 





20 


13 


65 





-86 


-9 


-11 


1 


1946 





-25 


-10 


-2 


-1 


5 


60 





-87 


-9 


-10 


-33 


1947 


-6 


20 


3 


-36 





-1 


67 





-87 


-11 


11 





1948 


8 


34 


24 


6 


1 





90 


-3 


-200 


-49 


-12 


-1 


1949 


-6 


26 


-18 


2 


12 


-24 


49 





-86 


-11 


-3 





1950 





24 


29 


43 


-150 





89 





-83 


-9 


-11 


28 


1951 


-4 


-6 


-8 








24 


89 





-86 


-9 


-10 


-10 


1952 


-6 


-42 


-10 


31 


-12 





90 





-117 





-17 


-14 


1953 


-26 


-3 








-2 


-1 


89 


89 


-3 


-141 


-19 


-16 


1954 


50 


-42 





-2 





-92 


90 





-85 


-8 


-10 


-10 


1955 


-7 


51 


-6 


-5 


-3 


-27 


28 





-87 


-10 


9 





1956 





-57 


3 


62 


5 


-83 


167 








-94 


-15 


51 


1957 


-19 


-5 


3 


-1 





-97 


44 


37 


-80 


-10 


-12 


-8 


1958 


-36 


-20 


-2 





55 


58 


90 





-106 





-12 


-24 


1959 


-10 


-7 


15 


-1 


-32 


-1 


46 


64 


-9 


-120 


-26 





1960 





-4 


18 





-1 


-45 


51 





-89 


-10 





-5 


1961 





20 


8 





-80 


-1 


63 


63 


-2 


-126 


-7 





1962 





46 


23 





43 


-100 


50 





-119 





-20 


-9 


1963 


-33 


-1 


-1 


-6 


4 





89 





-70 





-14 


-11 


1964 


-37 


-28 











12 


63 





-93 





-33 





1965 





23 


-60 








-5 


90 





10 


-99 





-16 


1966 


-38 


-10 


-3 








-1 


63 





-89 





-14 


-11 


1967 


-7 


10 


-23 


38 


-1 





90 





-91 





-11 


-34 


1968 


-9 


-4 


-1 








1 


64 





-87 


-10 





-19 


1969 


-6 


11 


-18 


13 








89 





-118 








-13 


1970 


-8 


-4 


-1 


52 


-11 


-45 


64 





-88 





-14 


-13 


1971 


-6 


-25 


-1 





-1 


-1 


91 





14 


-101 


-12 


-11 


1972 


-9 


-17 


-41 











46 





-90 





-14 


-12 


1973 


-3 


-12 


-2 


4 


42 


-11 


88 


2 


-86 





-15 


-13 


1974 


-4 


-25 














88 





14 


-102 


-15 


-16 


1975 


-10 


-51 





-1 








89 





-119 





-17 


8 


1976 


-8 


-3 


-4 








-38 


71 


69 


13 


75 


37 


15 


1977 


91 


61 


40 





-2 




















-89 


1978 





88 





96 


5 


7 











-142 


-120 


-117 


1979 


192 


91 


-482 


20 


-78 


-100 


89 





-142 


-15 


-12 





1980 


52 


-20 


-31 








-103 


89 


1 





-88 


-14 


-6 


1981 


-35 


-18 


-2 








-4 


63 





-89 


-13 


-12 


-2 


1982 








-17 





14 


30 


89 





-130 





-18 


-27 


1983 


-7 

















89 





-99 


-17 


-18 


-15 


1984 


-9 


30 


-22 











89 





-94 


-9 


-12 


15 


1985 


-9 


-12 





-24 


-49 





64 





-89 


-11 


-12 





1986 


-1 


33 





-79 


68 


-34 


89 








-80 


-17 


-11 


1987 


-8 


21 


-6 


-10 





-84 


75 


57 


40 


29 


82 


-4 


1988 


31 


58 


15 


-18 


-134 


-56 


46 


-12 


24 


111 


111 


2 


1989 


-12 


-4 


-12 


-8 


-26 


-100 








-142 


-117 


-129 


-135 


1990 


-51 


5 


6 


-7 





-1 


117 








37 


50 


154 


1991 


9 


223 


50 


4 


3 


1 


2 


1 





-34 


1 


-4 



AVG 3 10 -11 -1 8 -19 64 7 -68 -24 -13 



2-19 



QWEST (CFS) 

Existing Level of Demand, Mo-Action; D- K85*NMFS*USFWS OCAP BO 



167D 



YEAR 
1922 


OCT 
-508 


NOV 
-297 


DEC 
-924 


JAN 
706 


FEB 

8030 


HAR 
3167 


APR 
2701 


HAY 
9571 


JUN 
6370 


JUL 
■286 


AUG 

-2008 

-2005 

-506 


SEP 
-3294 
-3499 

366 
-3716 


1923 

1924 


-2799 
-1895 


71 
-827 


3500 
-2006 


3010 
■1000 











2262 




6070 
590 


3210 
■6 


■688 

■1006 


1925 


308 


-648 


■1355 


■645 


1891 





2006 


6897 


2555 


■430 


-2005 


1926 


-879 


-257 


-443 


-1000 








2174 


1714 


459 


■1003 


-2005 


-3827 


1927 


-1664 


-849 


-1939 


■1000 


8628 





5957 


8630 


3720 


423 


-2010 


-3438 


1928 


-3158 


-240 


-2000 


■1000 





8853 


2108 


5014 


1276 


-715 


-2005 


-3614 


1929 


-1865 


-1056 


-1478 


-1000 











1090 


1043 


■292 


-305 


■532 


1930 


-302 


■389 


-2000 


-1000 








22 


1829 


1995 


■14 


-2004 


■526 


1931 


355 


939 


636 


-1000 











845 


871 


12 


753 


■70 


1932 


104 


513 


-813 


-1000 











1885 


581 


■1004 


-2005 


-1787 


1933 


311 


-314 


-582 


-1000 











1260 


673 


■816 


■1998 


-685 


1934 


261 


660 


■2000 


-1000 











636 


1978 


1893 


■254 


-538 


1935 


668 


-737 


■694 


-1000 


-4 





7981 


7167 


2020 


-289 


-2005 


-3464 


1936 


-3429 


-1228 


■1409 


-920 


14058 





1488 


5498 


3216 


■242 


-2005 


-3495 


1937 


-2899 


-732 


-611 


■1000 


8719 


12769 


2073 


7641 


3354 


■591 


■2005 


-3306 


1938 


-2645 


-2000 


754 


-131 


30925 


34494 


9464 


19637 


15730 


1848 


-2005 


-1212 


1939 


4358 


-1801 


■2000 


-1002 








■9 


919 


■5 


■1006 


-2005 


-3777 


1940 


-997 


-328 


■1228 


■1000 


3572 


6266 


2156 


6453 


3323 


■340 


-2005 


-3503 


1941 


-2524 


-1593 


-872 


7263 


14324 


15487 


13673 


6713 


6084 


558 


-2007 


-3040 


1942 


1215 


-997 


3224 


10555 


13619 





7007 


5853 


2619 


684 


■2007 


-2090 


1943 


4895 


236 


-2000 


10913 


9062 


17196 


4063 


7117 


3206 


430 


-2010 


-3479 


1944 


-1745 


-2010 


■2007 


■1000 








■3 


1997 


626 


■1003 


-2005 


-3431 


1945 


-683 


-1549 


-587 


■1000 


6763 








5290 


2991 


-532 


-2010 


-3362 


1946 


-1152 


439 


5743 


966 








482 


4728 


2256 


-394 


-2005 


-3516 


1947 


-1630 


-899 


-1704 


■1000 











1601 


531 


-1003 


-2005 


-3380 


1948 


-991 


-919 


■706 


■1000 





■9 


1571 


3496 


2794 


-613 


-2006 


-3784 


1949 


-3574 


-2000 


■2008 


-1008 





680 


149 


2027 


523 


-1003 


-2005 


-2707 


1950 


-741 


-681 


■634 


-1000 








623 


5592 


2625 


-768 


■2005 


■3710 


1951 


-3670 


5170 


22147 


11514 


8979 


1909 


304 


6744 


1873 


-461 


■2005 


■3675 


1952 


-2828 


-1194 


1330 


14662 


8722 


10083 


10330 


15609 


11399 


2319 


■2005 


-740 


1953 


4445 


-1660 


-25 


5955 








457 


3408 





190 


■2006 


-3716 


1954 


-2949 


-592 


-2000 


-1000 








3452 


5311 


2593 


-535 


■2006 


-3704 


1955 


-3491 


-2000 


-2000 


-1000 











1827 


497 


-1004 


■2005 


-3903 


1956 


-1208 


-1444 


4783 


29549 


13328 





1119 


8314 


8549 


435 


■2005 


-3047 


1957 


5013 


-2000 


-2008 


-1000 











7225 


2652 


-875 


■2007 


-3676 


1958 


-1177 


-842 


-2000 


■833 


10925 


18461 


28173 


9819 


10979 


541 


-2010 


-2159 


1959 


5044 


-1753 


-2009 


■1000 


3593 








1579 


356 


-1004 


-2006 


■3878 


1960 


-2039 


-881 


-1407 


-1000 








■5 


3057 


1055 


-1007 


-2007 


■3872 


1961 


-1417 


-1479 


■2000 


-1000 








■2 


1461 


461 


-10C3 


-2005 


■2620 


1962 


-194 


-631 


■2000 


■1004 


4942 








4030 


1684 


-1006 


-2007 


■2969 


1963 


-4730 


-1793 


-2000 


•1000 


6152 





7430 


3373 


2527 


90 


-2006 


-3866 


1964 


-3030 


-2000 


-2000 


-1000 











1512 


605 


-1004 


-2005 


-3899 


1965 


-460 


-1983 


3498 


15885 


1785 





5338 


6872 


3385 


500 


-2008 


-3557 


1966 


1646 


-1834 


412 


■931 











3772 


951 


-1008 


-2006 


-3778 


1967 


-2648 


-1817 


325 


3998 


3324 


5232 


12415 


11720 


14389 


8696 


-2007 


■1119 


1968 


4830 


-1610 


-2001 


■1000 


3398 








3755 


942 


-1008 


■2004 


-3748 


1969 


-2022 


-2005 


■2000 


15699 


32382 


8335 


12100 


27087 


12170 


3157 


-2007 


-1770 


1970 


4307 


344 


1138 


25057 


7193 


1801 


■1 


4679 


1771 


-649 


-2006 


-3684 


1971 


-2979 


-2000 


4617 


■212 








1019 


4351 


4254 


131 


-2006 


-3682 


1972 


-2444 


-2000 


■559 


■1000 











3524 


967 


■1009 


-2007 


-3362 


1973 


-3196 


1537 


-2000 


4924 


13273 


7389 


253 


6342 


3161 


68 


-2006 


-3674 


1974 


-3222 


1504 


5487 


11707 


1285 


11149 


2862 


9139 


4541 


220 


-2006 


-3326 


1975 


909 


-177 


-689 


-1000 


8980 


9826 


1852 


5728 


1859 


-571 


-2005 


-2993 


1976 


1146 


598 


■1845 


-1000 











577 


■7 


-1006 


-2005 


-1645 


1977 


377 


-109 


■769 


-368 


-4 


■5 





490 


1025 


1592 


-95 


731 


1978 


1963 


1831 


■1862 


6432 


4457 


6745 


7621 


12494 


6102 


143 


-2005 


-3532 


1979 


-2203 


-2007 


■1099 


-1000 


6872 


2938 


1690 


5060 


1375 


-1006 


■2005 


-3536 


1980 


-2243 


291 


■736 


20312 


31151 


20935 


4340 


9135 


5529 


697 


■2010 


-2484 


1981 


2533 


-1234 


■1696 


■1000 











1969 


411 


-1004 


-2005 


-3526 


1982 


-1955 


-2000 


2657 


12742 


17306 


22506 


40237 


23633 


10939 


3484 


-2006 


1285 


1983 


6123 


8460 


26299 


31362 


51966 


71132 


39271 


34611 


34203 


20922 


910 


8529 


1984 


10594 


17715 


36271 


27941 


14074 


7795 


2774 


6601 


2460 


-308 


-2008 


-2110 


1985 


-1083 


-1080 


■1533 


-1000 








262 


2120 


509 


-1003 


-2005 


-3539 


1986 


-1655 


-1193 


-1879 


-1000 


39595 


38748 


17994 


10796 


3590 


-11 


-2007 


-2691 


1987 


159 


-1249 


-1046 


■1000 











951 


■4 


-1006 


-2006 


-1961 


1988 


923 


859 


■2000 


-1000 





■7 





672 


■6 


-1007 


-2005 


-1705 


1989 


-55 


-566 


■695 


-1000 








1157 


1918 


587 


-1003 


-2005 


-2636 


1990 


-659 


712 


■493 


-1000 











1040 


-7 


-1007 


-2005 


-1416 


1991 


470 


605 


112 


-340 











1060 


■3 


-1000 


-2007 


-1426 



AVG 



-381 



-300 



694 



3225 



5904 



4913 



3863 



5873 



3385 



193 -1827 -2550 



2-20 



Existing Level 


of Demand 


1; Pref 


erred Alternative 


Minus 


No-Action; 


D-1485- 


►NMFS+USFWS OCAP 


BO 167E-167D 


YEAR 


OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


1922 





22 


7 


-193 


21 


-100 





2 











-123 


1923 


-242 


-2 





























-103 


1924 


-6 





























208 





1925 


235 


47 


6 





5 





103 














-142 


1926 


-134 



































1927 








-61 





2 




















-122 


1928 


42 


-25 











-4 











1 





-30 


1929 


-7 





























109 


5 


1930 


251 


81 














41 











-4 


36 


1931 






































1932 


51 





1 


























-110 


1933 


-129 


1 




















353 


-147 


22 


179 


1934 
































10 





1935 














-4 





-1 














-123 


1936 


-118 


-133 





-46 


8 




















-123 


1937 


-118 


-22 








5 


71 











4 





-123 


1938 


-111 











62 


-36 


118 


60 











-195 


1939 


-153 


-4 


























-5 


37 


1940 


-48 











69 


54 


22 














-123 


1941 


-141 


-78 


-84 


30 


52 


8 


57 














-102 


1942 


-9 


-3 


-27 


























-94 


1943 


-9 


-3 





























-29 


1944 


-6 


1 





























-27 


1945 








-202 





-161 




















-141 


1946 





-51 





-19 

















-1 





-142 


1947 


-126 





-31 





























1948 


1 

















-23 














-126 


1949 


-142 





2 


8 





-1 




















1950 








28 




















2 





-125 


1951 


-90 


-84 








314 


-681 

















-123 


1952 


-23 


-14 


-1 


15 


-23 





118 


61 











-200 


1953 


-157 


-3 





























-123 


1954 


-157 


-4 





























-30 


1955 


-7 


























c 








1956 








-1 


71 


21 




















-200 


1957 


-200 





-1 


























-101 


1958 


-6 


-4 





-27 


55 


41 


57 














-134 


1959 


-11 


-6 
































1960 








-5 


























-121 


1961 


-17 


18 
































1962 





41 








44 




















-120 


1963 


-180 


-1 








-4 





56 














-120 


1964 


-48 



































1965 


-35 


-5 


-242 


-120 


2 




















-123 


1966 


-119 


-4 


-4 


























-118 


1967 


-58 


-62 


-9 


30 


-3 








61 











-200 


1968 


-143 


-4 


-1 


























-34 


1969 


-6 


-3 





15 





1 





61 











-200 


1970 


-155 


-4 


-1 


46 


-24 


207 

















-106 


1971 


42 








-1 























-103 


1972 


-10 





-63 


























-110 


1973 


-57 


-13 





4 


46 


-16 

















-123 


1974 


-42 


-41 











-1 


57 














-200 


1975 


-87 


-5 








-1 




















-162 


1976 


-7 


-3 


-3 


























212 


1977 


-1 


74 


50 


63 





1 














1 





1978 











78 


143 


16 

















-141 


1979 


-142 


1 


186 





-50 


-100 


26 

















1980 


6 


-200 


-200 


























-141 


1981 


-21 


-5 


-2 


























1 


1982 


-12 





-174 


15 





35 


118 














-178 


1983 


-7 














-26 


90 











-130 


-15 


1984 


-9 


14 


-7 


























-185 


1985 


-11 


-3 
































1986 





33 








71 


-99 

















-127 


1987 


-114 


51 


1 





























1988 





25 





























1 


1989 





84 





-4 























-121 


1990 


-137 


-8 


-1 





























1991 





11 





1 























-1 



AVG 



-42 



-4 



■12 



-9 



12 



-2 



•76 



2-21 



Chipps Island Electrical Conductivity iii%/cm) 100BH 

Existing Level of Demand, No-Action; 0-U85 



YEAR 
1922 


OCT 
12145 


NOV 
11382 


DEC 
7080 


JAN 
2735 


FEB 

317 


HAR 
323 


APR 

706 


HAY 
315 


JUN 
317 


JUL 
1344 


AUG 
4987 


SEP 
7410 
7154 


1923 


9241 


3684 


348 


327 


856 


4363 


1267 


1557 


2669 


4512 


5706 


1924 


9783 


11052 


9857 


8067 


7332 


9365 


11395 


11935 


13080 


14136 


15617 


17816 
9088 
9725 
6942 


1925 


17906 


16130 


13441 


12089 


316 


634 


1111 


1210 


1877 


3116 


5003 


1926 


11786 


12045 


12118 


6916 


339 


1835 


1874 


3111 


6112 


7096 


6973 


1927 


11927 


3314 


3352 


440 


315 


315 


315 


372 


814 


1972 


3740 


1928 


10188 


3379 


3738 


1241 


573 


315 


344 


2252 


4762 


4228 


4294 


7209 
15135 


1929 


10444 


11677 


10076 


8720 


6776 


7852 


10175 


11365 


12827 


10893 


11697 


1930 


16350 


16285 


12230 


1952 


2701 


546 


2073 


4742 


5679 


5935 


6045 


9264 


1931 


11813 


12052 


12120 


10211 


9717 


10992 


11825 


12055 


13116 


14147 


15621 


17630 


1932 


17684 


16807 


8894 


4132 


1411 


3863 


5714 


5169 


5737 


6331 


9262 


12841 


1933 


13187 


12132 


11935 


10014 


9734 


10783 


11551 


11978 


13093 


14140 


15619 


17382 


1934 


17393 


16690 


13127 


5412 


3976 


7454 


10865 


11790 


13037 


14122 


15612 


17220 
6237 


1935 


17206 


15512 


15204 


620 


964 


540 


316 


529 


1669 


3164 


4249 


1936 


9415 


11131 


9647 


450 


315 


324 


953 


1368 


1883 


3193 


4278 


6634 


1937 


9811 


9746 


10365 


9116 


320 


315 


580 


1558 


2497 


4897 


6537 


9831 


1938 


12128 


86fl 


315 


321 


315 


315 


315 


315 


315 


850 


3804 


5825 


1939 


1317 


2559 


6169 


7066 


5600 


6024 


6547 


8510 


11735 


9899 


7479 


10407 


1940 


12564 


9946 


10134 


675 


315 


315 


315 


519 


1846 


3151 


3908 


6260 


1941 


9674 


9960 


321 


315 


315 


315 


315 


315 


479 


1778 


3876 


7048 


1942 


4058 


2494 


315 


315 


315 


325 


315 


316 


351 


1330 


4033 


8493 


1943 


2317 


1505 


443 


315 


315 


315 


327 


786 


1057 


1983 


3937 


7106 


1944 


10193 


11610 


9897 


8083 


600 


984 


2745 


4416 


6299 


7179 


7802 


10775 


1945 


12433 


9802 


5364 


5913 


316 


400 


2346 


2769 


2746 


4594 


5783 


8246 


1946 


10864 


6520 


315 


315 


508 


801 


2698 


1899 


1906 


3108 


4337 


7763 


1947 


10926 


11723 


9001 


7605 


3211 


2218 


3791 


4937 


6376 


7146 


7465 


10089 


1948 


11950 


12091 


12131 


9391 


7597 


2827 


1583 


503 


898 


2604 


4131 


6472 


1949 


9691 


11130 


9707 


7837 


8161 


316 


1131 


4565 


6321 


7182 


7918 


10070 


1950 


11625 


12000 


12105 


3050 


351 


858 


2321 


2352 


2720 


4480 


5623 


7610 


1951 


9237 


324 


315 


315 


315 


320 


1135 


1274 


2967 


4052 


3935 


6155 


1952 


9580 


9140 


316 


315 


315 


315 


315 


315 


315 


848 


4228 


4307 


1953 


718 


2040 


317 


315 


327 


562 


1247 


456 


409 


1429 


3382 


6408 


1954 


8034 


2922 


4946 


605 


315 


315 


316 


661 


1853 


3112 


4181 


6401 


1955 


9604 


9410 


1428 


808 


3728 


7506 


5421 


4790 


6354 


7181 


7504 


9623 


1956 


11462 


11418 


315 


315 


315 


316 


647 


316 


368 


1450 


3725 


6491 


1957 


1589 


3218 


8315 


7372 


334 


315 


1213 


1883 


2367 


4447 


5624 


7114 


1958 


4378 


3098 


859 


322 


315 


315 


315 


315 


315 


887 


3627 


4169 


1959 


1097 


2995 


7912 


356 


315 


652 


3412 


4851 


6363 


7143 


6871 


8298 


1960 


10543 


9384 


9811 


9891 


699 


1050 


2662 


4309 


5607 


5870 


6224 


8995 


1961 


11368 


11135 


9117 


8232 


868 


1708 


4086 


4972 


6381 


7147 


7723 


10194 


1962 


11871 


12069 


9780 


9559 


315 


458 


2473 


2660 


2739 


4393 


6053 


8795 


1963 


530 


1191 


649 


1871 


315 


321 


315 


322 


705 


1967 


3404 


6368 


1964 


8282 


834 


3167 


1246 


3399 


7192 


5368 


4803 


6356 


7112 


6909 


9614 


1965 


11850 


10378 


315 


315 


317 


650 


315 


539 


1030 


1982 


3830 


7028 


1966 


7395 


787 


1750 


432 


414 


421 


2117 


4747 


5665 


5872 


5766 


7232 


1967 


9891 


9299 


321 


315 


315 


315 


315 


315 


315 


525 


3477 


3857 


1968 


630 


1878 


4755 


543 


315 


316 


1448 


4673 


5655 


5882 


5771 


8080 


1969 


10749 


9786 


2833 


315 


315 


315 


315 


315 


317 


1042 


3748 


4048 


1970 


906 


1397 


315 


315 


315 


315 


945 


3830 


4942 


4257 


3955 


6564 


1971 


10020 


2572 


315 


315 


378 


315 


622 


353 


524 


1723 


3409 


6417 


1972 


7564 


7316 


3260 


2645 


989 


355 


1732 


4658 


5653 


5884 


5772 


7217 


1973 


9423 


3724 


674 


315 


315 


315 


703 


1473 


1087 


1984 


3788 


6857 


1974 


9775 


315 


315 


315 


315 


315 


315 


344 


640 


1796 


3673 


4848 


1975 


2802 


2510 


2870 


4285 


315 


315 


387 


330 


378 


1795 


4202 


6436 


1976 


2518 


2106 


4407 


7193 


5148 


5865 


8252 


10362 


12582 


10636 


8873 


11932 


1977 


15001 


12061 


10578 


11177 


11684 


12017 


12110 


12136 


13140 


14155 


15624 


18124 


1978 


18276 


17049 


12239 


315 


315 


315 


315 


370 


798 


1971 


3684 


6824 


1979 


9566 


10203 


11038 


1627 


316 


322 


1158 


2581 


5012 


6963 


6975 


7888 


1980 


9988 


4737 


1930 


315 


315 


315 


390 


881 


1018 


1981 


3652 


7794 


1981 


4815 


5205 


6734 


2336 


659 


334 


1632 


4693 


6340 


7142 


6878 


8892 


1982 


11135 


552 


315 


315 


315 


315 


315 


315 


337 


1325 


4022 


1805 


1983 


328 


315 


315 


315 


315 


315 


315 


315 


315 


317 


1164 


442 


1984 


319 


315 


315 


315 


315 


315 


757 


2240 


3895 


4282 


4180 


6553 


1985 


4824 


359 


394 


2382 


2285 


1466 


3260 


4876 


6367 


7143 


6877 


8574 


1986 


10814 


10733 


7226 


2560 


315 


315 


316 


700 


3105 


4858 


4973 


7417 


1987 


9145 


10452 


11482 


9161 


4355 


673 


2631 


7796 


11553 


9906 


8367 


10866 


1988 


12401 


12220 


9224 


1018 


3069 


8711 


10512 


11213 


12826 


10191 


9762 


12756 


1989 


14966 


14851 


14188 


11885 


10748 


336 


789 


3366 


5499 


5737 


5616 


6626 


1990 


9203 


11242 


10482 


6662 


6565 


8879 


8876 


9652 


12149 


10561 


12253 


15754 


1991 


16431 


16085 


15317 


13751 


12446 


1114 


3235 


9167 


12278 


10952 


12370 


14348 



AVG 9358 7755 6013 3666 2132 2039 2697 3538 4553 5234 6306 8597 



2-22 



Chipps Island Electrical Conductivity (/iS/cm) 

Existing Level of Demand, Preferred Alternative Minus No-Action; D-H85 100BU-100BH 



YEAR 


OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


1922 





38 


8 


81 








-6 








-27 


-71 


-27 


1923 


116 


47 








1 





37 


14 


1 


-6 


-8 


-4 


1924 








12 


9 


2 




















153 


1925 


183 


74 


25 


7 








5 


2 





-62 


-27 


-120 


1926 


-145 


-41 


-12 


-3 





6 


-9 


-5 


-1 


-6 


-1 


2 


1927 








11 


11 




















-3 


-10 


1928 


-8 


121 


57 


2 











-10 


-1 


-8 


-8 


-3 


1929 








22 


17 


3 


-1 


-1 





1 


84 


180 


146 


1930 


54 


20 


7 


-1 


89 


7 


3 








-84 


124 


93 


1931 


-35 


-9 


-3 


-1 


























1932 








-8 


52 


-152 


-167 


-22 


-3 


-1 


51 


50 


14 


1933 


4 


58 


54 


12 


2 























1934 








-43 


-20 


-259 


-262 


-62 


-17 


-5 


-2 








1935 





























-63 


-86 


-52 


1936 


-124 


-98 


-9 


2 








-8 


-8 





-1 


-8 


14 


1937 


20 


25 


18 


5 








-6 


-8 


-1 





-6 


-3 


1938 


1 


25 























2 


-10 


34 


1939 


11 


7 


6 


1 





-1 











30 


9 


7 


1940 


13 


20 


15 


-6 

















-63 


-83 


-39 


1941 


-5 


1 


1 

















4 


10 


-4 


-10 


1942 


10 


6 




















1 


5 


-4 


7 


1943 


12 


3 














-1 


-2 








-4 


-10 


1944 


-7 


-2 


5 


4 


1 


1 


19 


16 


2 


-4 


-2 





1945 





-72 


271 


194 





-1 


-2 








-6 


-9 


5 


1946 


9 


91 











-1 











-6 


-8 


-39 


1947 


-39 


19 


63 


3 


-7 














-5 


4 


7 


1948 


2 


1 





4 


4 





-24 





26 


44 


12 


7 


1949 


6 


30 


11 


-3 


5 





9 


22 


3 


-3 


2 


3 


1950 


1 








-27 


1 


3 


-35 


-18 


-1 


-6 


-8 


31 


1951 


28 

















-15 


-7 


-1 


-7 


-7 


-3 


1952 





188 























2 


-16 





1953 


7 


8 














-17 


-4 


-1 











1954 


34 


82 


52 


2 











-1 





-5 


-7 


-4 


1955 


-1 


58 


11 


4 


10 


3 


21 


11 


2 


-3 


6 


7 


1956 


1 


200 














-12 











6 


24 


1957 


17 


12 


6 


2 


1 





13 


-32 


-20 


-8 


-8 


-3 


1958 


81 


63 


4 




















2 


-8 


11 


1959 


4 


6 


18 








1 


33 


27 


4 


-79 


-38 


5 


1960 


1 


-3 


22 


20 


1 





18 


15 


2 


-8 





-5 


1961 


-8 


34 


37 


12 


13 


8 


1 








-57 


-38 


-4 


1962 


-1 


-1 


12 


9 





3 


36 


14 


1 





-9 


-19 


1963 


5 


4 





2 




















-6 


-12 


1964 


-5 


27 


32 


1 





8 


48 


24 


4 





-7 


-7 


1965 


-2 


22 











1 

















-13 


1966 


111 


13 


8 











1 











-7 


-13 


1967 


-9 


5 























1 


-10 


35 


1968 


3 


2 


2 




















-8 


-3 


3 


1969 


3 


13 


13 




















2 


-1 


9 


1970 


2 


1 














1 











-7 


-4 


1971 


1 


42 














-6 








-2 








1972 


8 


57 


99 


31 


1 





16 


25 


3 


1 


-8 


-4 


1973 


-3 


28 


3 











-7 


-9 


-1 





-6 


-14 


1974 


-15 




















-1 


-1 


-2 


6 


17 


1975 


10 


73 


39 


5 








-1 





2 


9 


1 


5 


1976 


6 


3 


5 


3 


1 


34 


149 


119 


34 


114 


113 


73 


1977 


39 


9 


56 


50 


12 


4 


1 


1 














1978 
































-44 


-127 


1979 


99 


234 


112 


-1 





1 


-12 


-18 


-2 


-7 


-8 


-2 


1980 


92 


102 


25 











-2 


-4 








4 


-6 


1981 


76 


85 


43 


3 








1 








-6 


-7 


-5 


1982 


-4 























1 


6 


-11 


18 


1983 
































3 


1 


1984 




















-9 


-14 


-2 


-8 


-8 


11 


1985 


13 


1 





31 


37 


5 











-5 


-5 


-2 


1986 


-1 


49 


32 


36 











-1 











-11 


1987 


1 


8 


-43 


-41 


-6 


8 


12 


2 


4 


26 


42 


19 


1988 


-2 





-21 


1 


-39 


-71 


72 


78 


40 


22 


14 


16 


1989 


8 


-3 


-26 


-34 


-46 





1 


1 





-77 


-87 


-60 


1990 


-5 


18 


11 


11 


5 


-2 


-2 








53 


48 


-238 


1991 


-279 


125 


402 


265 


90 


3 








-1 


-52 


-49 


-25 



AVE 



28 



21 



11 



2-23 



Percentage Difference, Chipps Island Electrical Conductivity ^^S/cm) . ,qqbh 
Existing Level of Demand, Preferred Alternative Minus No-Action; u- i-oj 

YEAR OCT NOV DEC JAN FEB MAR APR MAY JUN JUL AUG SEP 



1922 0-5 0-1 3.0 -0.8 2.0 

1923 1.3 1.3 0.1 2-9 0.9 0.1 0.1 u. 

192' ° 0.1 0.1 ° ° n? S -2 -0 5 -13 

1925 1.0 0.5 0.2 0.1 0.5 0.2 2.0 u.5 i.^ 

1926 -1.2 -0.3 -0.1 0.3 -0.5 

1927 0.3 2.5 



-0.2 -0.1 

-0.1 -0.1 

-0.2 -0.2 



1928 -0.1 3.6 1.5 0.2 -0.4 - -■- - 

1929 0.2 0.2 _0 0.8 1.5 1.0 



1 0.8 0.5 0.1 



0.1 

-2.0 -2.0 -0.8 



1930 0.3 0.1 0.1 -0.1 3.3 1.3 0.1 

1931 -0.3 -0.1 

1932 -0.1 1.3 -10.8 -4.3 -0.4 

1933 0.5 0.5 0.1 

1934 -0.3 -0.4 -6.5 -3.5 -0.6 

1935 „nt>n5 

1936 -1.3 -0.9 -0.1 0.4 -0.8 -0.6 -0 0. 

1937 0.2 0.3 0.2 0.1 -1.0 -0.5 0.1 



1938 2.9 

1939 0.8 0.3 0.1 

1940 0.1 0.2 0.1 -0.9 

1941 -0.1 0.3 

1942 0.2 0.2 



0.2 -0.3 0.6 

0.3 0.1 0.1 

-2.0 -2.1 -0.6 

0.8 0.6 -0.1 -0.1 

0.3 0.4 -0.1 0.1 

1943 0:5 0:1 S 5 -0.3 -0.3 -0.1 -0.1 

1944 -0 1 0.1 0.2 0.1 0.7 0.4 -0.1 

945 -0.7 5.1 3.3 -0.3 -0.1 -0.1 -0.2 0.1 

946 0.1 1.4 -0.1 -0 -0 - . 

1947 -0.4 0.2 0.7 -0.2 ^ -^l I'l °- 

1948 0.1 -1.5 2.9 1.7 0.3 0.1 

1949 0.1 0.3 0.1 0.1 0.8 0.5 ° „ ? „ ? 
950 -0.9 0.3 0.3 -1.5 -0.8 -0.1 -0.1 0.4 
91 0.3 -1.3 -0.5 -0. -0.2 

1952 2.1 0.2 -0.4 

1953 1.0 0.4 -1.4 -0.9 -0.2 

1954 0.4 2.8 1.1 0.3 -0.2 -0.2 -0.2 -0. 

1955 0.6 0.8 0.5 0.3 0.4 0.2 0.1 0.1 

1956 1.8 -1.9 0.2 0.4 

1957 1.1 0.4 0.1 0.3 1.1 -1.7 -0.8 -0.2 -0.1^ ^ 

1958 1.9 2.0 

1959 0.4 

1960 

1961 -0.1 

1962 

1963 0.9 
1964 
1965 
1966 
1967 



05 0. 2 -0.2 0.3 

0*2 02 0.2 1.0 0.6 0.1 -1.1 -0.6 0.1 

'0 2 0.2 0.1 0.7 0.3 -0.1 -0.1 

3 4 0.1 1.5 0.5 -0.8 -0.5 

10 1 0.7 1.5 0.5 -0.1 -0.2 

03 0.1 -0.2 -0.2 

-o'l 3 2 10 0.1 0.1 0.9 0.5 0.1 -0.1 -0.1 

'002 0.2 -0.2 

151705 -0.1 -0.2 

-o'l 01 0. 2 -0.3 0.9 



1968 0.5 0.1 -0.1 -0.1 

1969 0.1 0.5 0.2 0.2 

1970 0.2 0.1 0.1 -0.2 -0.1 
1971 
1972 
1973 



16 -1.0 -0.1 

1 8 3.0 1.2 0.1 0.9 0.5 0.1 -0.1 -0.1 

00804 -1.0 -0.6 -0.1 -0.2 -0.2 



1974 -02 -0.3 -0.2 -0.1 0.2 0.4 

1975 4 2.9 1.4 0.1 -0.3 0.5 0.5 0.1 

1976 2 0.1 0.1 0.6 1.8 1.1 0.3 1.1 1.3 0.6 

1977 3 0.1 0.5 0.4 0.1 

1978 0000000000 -1.2 -1.9 

1979 1 2.3 1.0 -0.1 0.3 -1.0 -0.7 -0.1 -0.1 

1980 9 2.2 1.3 -0.5 -0.5 0.1 -0.1 

1981 1.6 1.6 0.6 0.1 0.1 -0.1 -0.1 -0.1 

1982 0.3 0.5 -0.3 1.0 

1983 0.3 0.2 

1984 -1.2 -0.6 -0.1 -0.2 -0.2 0.2 

1985 0.3 0.3 1.3 1.6 0.3 -0.1 -0.1 

1986 0.5 0.4 1.4 -0.1 -0.1 

1987 0.1 -0.4 -0.4 -0.1 1.2 0.5 0.3 0.5 0.2 

1988 -0.2 0.1 -1.3 -0.8 0.7 0.7 0.3 0.2 0.1 0.1 

1989 0.1 -0.2 -0.3 -0.4 0.1 -1.3 -1.5 -0.9 

1990 -0.1 0.2 0.1 0.2 0.1 0.5 0.4 -1.5 

1991 -1.7 0.8 2.6 1.9 0.7 0.3 -0.5 -0.4 -0.2 

AVE 0.2 0.6 0.4 0.2 -0.1 0.1 -0.1 -0.1 



2-24 



Chipps Island Electrical Conductivity (MS/cm) 

Existing Level of Demand, No-Action; 0-K85+NMFS+USFUS OCAP BO 167D 



YEAR 


OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


1922 


12145 


12147 


7565 


2694 


316 


321 


408 


315 


316 


1356 


4937 


6512 


1923 


6788 


2947 


347 


333 


784 


2221 


484 


755 


1712 


4375 


6740 


7176 


1924 


8731 


10789 


10505 


8477 


2547 


4538 


6182 


8436 


11137 


12330 


13478 


16243 


1925 


17376 


15933 


13179 


11786 


315 


420 


422 


550 


1220 


3292 


5195 


6458 


1926 


9199 


11352 


11923 


5724 


325 


785 


488 


2103 


5383 


8477 


9159 


7712 


1927 


8976 


2966 


1655 


337 


315 


315 


315 


337 


738 


1968 


3832 


6032 


1928 


7687 


2780 


3660 


761 


426 


315 


324 


1051 


3145 


5270 


5896 


6523 


1929 


8668 


10830 


11413 


8828 


2380 


2356 


4244 


7501 


10456 


12627 


14295 


14835 


1930 


15358 


15915 


10725 


787 


740 


350 


1072 


3655 


4975 


7169 


7687 


10165 


1931 


12237 


12173 


12154 


8721 


4496 


5947 


6330 


7950 


10616 


12672 


15122 


16330 


1932 


16335 


16279 


7184 


2839 


1502 


2884 


4009 


4167 


4783 


7137 


7928 


8737 


1933 


10628 


11726 


12027 


7645 


3103 


2891 


4418 


7238 


10136 


11882 


10170 


10968 


1934 


13850 


15382 


11884 


3893 


1542 


2267 


4198 


7950 


10937 


12763 


13332 


13710 


1935 


14901 


14265 


13781 


617 


975 


451 


315 


398 


1154 


3286 


5164 


6467 


1936 


7663 


9829 


11404 


399 


315 


323 


476 


1006 


1500 


3314 


5161 


6438 


1937 


7892 


10060 


11575 


8915 


318 


315 


379 


713 


1616 


4374 


6724 


7258 


1938 


8235 


659 


315 


326 


315 


315 


315 


315 


315 


834 


3669 


5679 


1939 


1324 


2724 


6985 


7570 


3829 


2606 


4076 


7650 


10621 


12172 


10373 


7970 


1940 


9447 


11416 


11781 


612 


315 


315 


315 


426 


1309 


3299 


4737 


6148 


1941 


8079 


9976 


317 


315 


315 


315 


315 


315 


427 


1672 


3786 


6349 


1942 


3223 


2257 


315 


315 


315 


322 


315 


316 


339 


1276 


3732 


6783 


1943 


1633 


1390 


509 


315 


315 


315 


319 


496 


904 


1976 


3832 


6000 


1944 


8766 


10189 


10317 


7568 


531 


489 


2346 


4753 


5726 


8543 


9169 


7950 


1945 


9569 


8809 


4163 


4545 


315 


363 


1454 


1942 


2042 


4410 


6704 


7315 


1946 


9476 


2826 


315 


315 


419 


526 


1369 


1459 


1519 


3316 


5190 


6555 


1947 


9044 


11121 


8388 


8050 


1606 


630 


1562 


3778 


5597 


8518 


9223 


8045 


1948 


9626 


11462 


11953 


7373 


4498 


2180 


365 


326 


622 


2799 


5170 


6353 


1949 


7497 


7408 


8568 


9378 


4309 


316 


808 


3423 


5315 


8464 


9145 


8657 


1950 


10207 


11614 


11996 


1239 


331 


439 


678 


1056 


1809 


4377 


6756 


7050 


1951 


7525 


316 


315 


315 


315 


318 


616 


689 


2275 


4499 


4963 


6126 


1952 


7847 


4405 


316 


315 


315 


315 


315 


315 


315 


686 


3304 


3934 


1953 


957 


2257 


317 


315 


330 


483 


660 


360 


372 


1357 


3879 


6007 


1954 


5597 


2169 


4338 


418 


315 


315 


315 


572 


1426 


3305 


5308 


6471 


1955 


7623 


6224 


697 


568 


1485 


2874 


4002 


4610 


5599 


8518 


9269 


7747 


1956 


9346 


11279 


315 


315 


315 


316 


430 


315 


351 


1383 


3875 


5783 


1957 


1191 


2827 


7423 


8184 


333 


315 


1005 


595 


1319 


4331 


6922 


7186 


1958 


1996 


1467 


544 


322 


315 


315 


315 


315 


315 


869 


3803 


4288 


1959 


1017 


2450 


6873 


354 


315 


447 


2291 


4049 


5394 


8479 


9325 


7603 


1960 


8547 


10700 


11673 


9479 


440 


370 


1976 


3962 


4588 


7096 


8017 


7363 


1961 


9309 


11083 


4731 


4804 


349 


535 


2652 


4807 


5733 


8544 


9268 


8854 


1962 


10328 


11646 


7189 


7583 


315 


341 


1494 


2342 


2178 


4432 


6953 


8040 


1963 


394 


1074 


431 


470 


315 


320 


315 


318 


656 


1964 


3978 


5975 


1964 


5372 


458 


2429 


748 


1197 


2894 


4221 


4869 


5742 


8546 


9210 


7729 


1965 


9359 


10039 


315 


315 


317 


427 


315 


409 


887 


1975 


3847 


6038 


1966 


3461 


585 


1618 


428 


377 


411 


1248 


2347 


3949 


6993 


8027 


7322 


1967 


8125 


5133 


318 


315 


315 


315 


315 


315 


315 


417 


2436 


4012 


1968 


912 


2100 


4780 


458 


315 


317 


1278 


2756 


3962 


6995 


7819 


7332 


1969 


8686 


9885 


772 


315 


315 


315 


315 


315 


316 


1013 


3762 


4058 


1970 


994 


1438 


315 


315 


315 


316 


973 


2017 


3199 


4598 


5093 


6191 


1971 


7769 


742 


315 


315 


351 


315 


398 


326 


452 


1623 


3914 


6017 


1972 


4797 


4942 


2454 


2358 


554 


336 


1276 


2645 


3996 


7001 


8154 


7556 


1973 


6980 


966 


378 


315 


315 


315 


463 


693 


917 


1977 


3977 


6026 


1974 


7565 


315 


315 


315 


315 


315 


315 


327 


523 


1685 


3911 


5036 


1975 


1790 


2075 


2830 


3692 


315 


315 


342 


320 


356 


1933 


5068 


5529 


1976 


1298 


1209 


3654 


6363 


1448 


1389 


3545 


7917 


11010 


12453 


10518 


9625 


1977 


12362 


14886 


15228 


13840 


12653 


12295 


8187 


7846 


10268 


12575 


14131 


16811 


1978 


17737 


16828 


13027 


315 


315 


315 


315 


337 


725 


1968 


3877 


6103 


1979 


8396 


9716 


10914 


1368 


317 


322 


618 


1084 


3470 


8124 


9099 


7766 


1980 


6312 


2254 


1581 


315 


315 


315 


359 


584 


904 


1976 


3845 


6732 


1981 


3310 


4417 


6474 


1443 


434 


355 


1187 


3740 


5592 


8517 


9201 


7752 


1982 


8618 


347 


315 


315 


315 


315 


315 


315 


331 


1045 


3384 


2083 


1983 


330 


315 


315 


315 


315 


315 


315 


315 


315 


316 


1086 


442 


1984 


319 


315 


315 


315 


315 


315 


502 


1017 


2705 


4551 


4919 


4349 


1985 


2926 


339 


389 


2365 


1262 


830 


2251 


4302 


5666 


8531 


9163 


7737 


1986 


9019 


11031 


7482 


1067 


315 


315 


315 


447 


2022 


4281 


4824 


6585 


1987 


8421 


10112 


11467 


9797 


1652 


396 


2010 


7315 


10543 


12159 


10378 


9491 


1988 


10804 


llf-Zi 


8253 


593 


1620 


6667 


7025 


8226 


10865 


12255 


10414 


9775 


1989 


12516 


14936 


15335 


12930 


10271 


316 


387 


2282 


4817 


7143 


7897 


8025 


1990 


9973 


11552 


11979 


5475 


2032 


2767 


4477 


7094 


10013 


12058 


10379 


10070 


1991 


12830 


15039 


15799 


14390 


11506 


538 


1206 


5458 


9903 


10452 


9132 


9801 



AVE 7675 7127 5878 3360 1334 1106 1559 2561 3724 5608 6895 7483 



2-25 



Chipps Island Electrical Conductivity (/iS/cm) ..„,,.- n^,„ on ii7c iath 
Existing Level of Demand, Preferred Alternative Minus No-Action; D-U85*NMFS*USFUS OCAP BO 167E-167D 

YEAR OCT NOV DEC 

1922 -10 

1923 376 136 

1924 -48 -12 -3 

1925 165 130 75 

1926 

1927 62 

1928 15 58 24 

1929 -U -4 -1 

1930 146 54 -542 

1931 64 18 5 

1932 

1933 -101 -27 -7 

1934 391 135 -272 

1935 15 5 2 

1936 -42 -13 -11 

1937 -40 

1938 -56 48 

1939 58 26 27 

1940 

1941 -53 -109 1 

1942 -10 2 

1943 -7 2 9 

1944 -15 -4 -1 

1945 -14 -3 150 

1946 90 

1947 -90 -90 113 

1948 

1949 -42 337 287 

1950 

1951 -39 

1952 -4 46 

1953 38 22 

1954 103 35 5 

1955 -12 27 4 

1956 

1957 64 34 5 

1958 -8 1 

1959 13 5 5 

1960 -7 

1961 23 61 

1962 0-33 

1963 7 10 

1964 -5 

1965 7 

1966 144 7 4 

1967 -52 176 

1968 34 18 3 

1969 -4 1 

1970 40 13 

1971 -15 9 

1972 -20 2 95 

1973 130 20 1 

1974 -49 

1975 64 15 2 

1976 21 2 3 

1977 227 74 197 

1978 1 1 

1979 

1980 -23 76 77 

1981 -16 -6 4 

1982 -10 

1983 

1984 

1985 58 

1986 

1987 90 129 43 

1988 

1989 

1990 9 2 

1991 



JAN 


FEB 


HAR 


APR 


HAY 


JUN 


JUL 


AUG 


SEP 


86 























-61 








9 


1 














-57 























372 


419 


16 








-19 


-9 




















1 












































-64 




















-3 


-2 


-17 























414 


435 


-25 








-47 


-82 


-10 


-2 


-2 


58 


1 





























-18 


-14 


-1 














-105 


-2 


121 


52 


6 


1 





-499 


-311 


345 


100 


-3 

















46 


46 


























-61 


8 























-61 




















-11 


-11 


-70 


























163 


18 


2 

















-7 


-3 


























-59 


























-39 


























-55 


























-14 


-1 























-16 


85 





1 























1 























91 


4 
































2 














-52 


55 


3 























-2 

















-5 


-5 


-61 








1 


7 














-57 


























135 


























-56 


6 























-15 





















































181 


























-52 


1 























96 





























■6 


























27 


























-23 























10 


2 























-67 





















































-58 


























-59 


























136 





















































138 











-4 


-1 











-49 


























-48 


38 


1 




















-62 


























-57 


























164 


























143 


2 























221 


183 


56 


17 


4 


1 








3 


3 





























-15 








-12 


-10 









































1 


-1 


2 


9 














-1 


























67 























20 


2 


























135 





























-2 























-49 


11 





-1 


-4 


-1 








1 


1 























2 


1 


7 


5 




















9 

























































AVE 



21 



22 



-1 



-7 



21 



2-26 



Percentage Difference, Chipps Island Electrical Conductivity ((iS/cm) 

Existing Level of Demand, Preferred Alternative Minus No-Action; D-K85+NMFS+USFWS OCAP BO 167E-167D 



YEAR 


OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


1922 








-0.1 


3.2 























-0.9 


1923 


5.5 


4.6 











0.4 


0.2 














-0.8 


1924 


-0.5 


-0.1 


























2.8 


2.6 


1925 


0.9 


0.8 


0.6 


0.1 








-4.5 


-1.6 














1926 

















0.1 




















1927 








3.7 


























-1.1 


1928 


0.2 


2.1 


0.7 




















-0.1 





-0.3 


1929 


-0.2 





























2.9 


2.9 


1930 


1.0 


0.3 


-5.1 


-3.2 








-4.4 


-2.2 


-0.2 








0.6 


1931 


0.5 


0.1 























c 








1932 














-1.2 


-0.5 

















-1.2 


1933 


-1.0 


-0.2 


-0.1 





3.9 


1.8 


0.1 








-4.2 


-3.1 


3.1 


1934 


2.8 


0.9 


-2.3 


-2.6 


-0.2 

















0.3 


0.3 


1935 


0.1 
































-0.9 


1936 


-0.5 


-0.1 


-0.1 


2.0 























-0.9 


1937 


-0.5 


























-0.3 


-0.2 


-1.0 


1938 


-0.7 


7.3 





























2.9 


1939 


4.4 


1.0 


0.4 


0.2 


0.1 

















-0.1 





1940 



































-1.0 


1941 


-0.7 


-1.1 


0.3 


























-0.6 


1942 


-0.3 


0.1 





























-0.8 


1943 


-0.4 


0.1 


1.8 


























-0.2 


1944 


-0.2 
































-0.2 


1945 


-0.1 





3.6 


1.9 





0.3 




















1946 





3.2 








0.2 























1947 


-1.0 


-0.8 


1.3 


1.1 


0.2 























1948 




















0.5 














-0.8 


1949 


-0.6 


4.5 


3.3 


0.6 


0.1 























1950 











-0.2 

















-0.1 


-0.1 


-0.9 


1951 


-0.5 














0.3 


1.1 














-0.9 


1952 


-0.1 


1.0 





























3.4 


1953 


4.0 


1.0 





























-0.9 


1954 


1.8 


1.6 


0.1 


1.4 























-0.2 


1955 


-0.2 


0.4 


0.6 





























1956 



































3.1 


1957 


5.4 


1.2 


0.1 


C 























-0.7 


1958 


-0.4 


0.1 





0.3 























2.2 


1959 


1.3 


0.2 


0.1 





























1960 








-0.1 


-0.1 


























1961 





0.2 


1.3 


0.6 


























1962 








-0.5 


-0.3 























0.1 


1963 


1.8 


0.9 





0.4 























-1.1 


1964 


-0.1 



































1965 





0.1 





























-1.0 


1966 


4.2 


1.2 


0.2 


























-0.8 


1967 


-0.6 


3.4 





























3.4 


1968 


3.7 


0.9 


0.1 





























1969 








0.1 


























3.4 


1970 


4.0 


0.9 














-0.4 














-0.8 


1971 


-0.2 


1.2 





























-0.8 


1972 


-0.4 





3.9 


1.6 


0.2 




















-0.8 


1973 


1.9 


2.1 


0.3 


























-0.9 


1974 


-0.6 
































3.3 


1975 


3.6 


0.7 


0.1 


























2.6 


1976 


1.6 


0.2 


0.1 


























2.3 


1977 


1.8 


0.5 


1.3 


1.3 


0.4 


0.1 




















1978 






































1979 











-1.1 








-1.9 


-0.9 














1980 


-0.4 


3.4 


4.9 





























1981 


-0.5 


-0.1 


0.1 


0.1 


-0.2 


0.6 


0.8 

















1982 


-0.1 
































3.2 


1983 
































1.8 


0.5 


1984 



































3.1 


1985 


2.0 



































1986 











-0.2 























-0.7 


1987 


1.1 


1.3 


0.4 


0.1 





-0.3 


-0.2 

















1988 






































1989 











0.1 























0.1 


1990 


0.1 



































1991 







































AVE 



0.6 



0.6 



0.3 



0.1 



0.1 



-0.1 -0.1 



-0.1 



0.1 



0.3 



2-27 



Total Delta Exports <Banks«North Bay Aqueduct*Tracy*Contra Costa Canal) (TAF) ^^^^^ 

Existing Level of Demand, No-Action; 0-U85 



YEAR 
1922 


OCT 

408 


NOV 
556 


DEC 
703 


JAN 
718 


FEB 
653 


HAR 
713 


APR 
678 


MAY 
384 


JUN 
376 


JUL 
529 


AUG 
620 


SEP 
578 
614 
243 
386 


TOTAL 
6916 
7158 
5139 
6106 
6370 
6727 
7013 
5626 
6250 
4142 


1923 


591 


664 


703 


718 


621 


624 


628 


379 


316 


586 


715 


1924 


487 


549 


684 


716 


644 


432 


412 


286 


265 


223 


196 


1925 


310 


448 


556 


502 


655 


707 


678 


383 


316 


586 


579 


1926 


435 


432 


461 


715 


653 


693 


677 


322 


315 


585 


707 


375 


1927 


421 


663 


698 


709 


643 


547 


560 


384 


316 


586 


671 


530 


1928 


461 


664 


703 


718 


653 


713 


615 


379 


316 


586 


715 


490 


1929 


442 


533 


684 


641 


653 


562 


369 


322 


313 


504 


318 


284 


1930 


290 


384 


633 


712 


655 


710 


537 


379 


315 


585 


670 


380 


1931 


409 


464 


475 


624 


542 


263 


293 


250 


234 


124 


199 


265 


1932 


216 


312 


700 


712 


534 


424 


511 


343 


316 


546 


318 


348 


5280 


1933 


307 


479 


502 


666 


521 


544 


271 


248 


238 


218 


218 


292 


4504 


1934 


284 


259 


583 


715 


598 


500 


293 


269 


228 


133 


212 


284 


4360 


1935 


238 


459 


397 


522 


200 


713 


678 


384 


316 


586 


715 


674 


5882 


1936 


456 


517 


684 


718 


653 


713 


678 


363 


316 


586 


715 


579 


6979 


1937 


409 


617 


510 


718 


653 


713 


677 


383 


314 


497 


611 


408 


6512 


1938 


467 


663 


702 


718 


653 


532 


469 


384 


376 


366 


590 


687 


6606 


1939 


693 


664 


703 


689 


532 


527 


537 


324 


315 


587 


712 


355 


6638 


1940 


379 


632 


492 


719 


647 


713 


678 


378 


316 


586 


715 


593 


6850 


1941 


430 


581 


703 


718 


653 


661 


661 


384 


376 


448 


617 


578 


6809 


1942 


693 


664 


703 


718 


653 


553 


571 


384 


376 


554 


612 


552 


7033 


1943 


693 


664 


703 


718 


637 


550 


571 


384 


316 


581 


612 


530 


6959 


1944 


592 


445 


684 


718 


653 


713 


658 


379 


316 


586 


579 


383 


6707 


1945 


421 


664 


703 


718 


653 


617 


557 


379 


316 


586 


715 


491 


6819 


1946 


581 


663 


702 


718 


653 


557 


567 


323 


316 


586 


684 


447 


6798 


1947 


450 


568 


703 


704 


653 


708 


527 


322 


316 


586 


635 


382 


6554 


1948 


460 


488 


448 


689 


614 


711 


678 


383 


376 


586 


715 


578 


6725 


1949 


464 


521 


660 


714 


558 


709 


600 


379 


315 


585 


542 


409 


6456 


1950 


436 


457 


443 


717 


652 


711 


678 


379 


316 


586 


715 


517 


6609 


1951 


547 


663 


702 


718 


653 


579 


575 


384 


316 


586 


715 


608 


7048 


1952 


429 


664 


703 


718 


653 


615 


559 


384 


376 


496 


540 


687 


6823 


1953 


693 


664 


703 


718 


449 


484 


571 


384 


376 


586 


715 


549 


6892 


1954 


662 


664 


650 


716 


653 


636 


575 


375 


316 


586 


715 


616 


7166 


1955 


448 


660 


702 


718 


589 


615 


614 


379 


316 


586 


641 


409 


6676 


1956 


429 


507 


703 


718 


653 


669 


594 


384 


376 


507 


612 


639 


6790 


1957 


693 


664 


483 


718 


653 


661 


575 


384 


316 


586 


715 


609 


7058 


1958 


693 


664 


703 


718 


653 


539 


558 


384 


376 


444 


621 


687 


7040 


1959 


693 


664 


579 


718 


612 


534 


549 


323 


316 


586 


715 


469 


6759 


1960 


424 


643 


499 


586 


653 


698 


677 


379 


315 


585 


658 


410 


6529 


1961 


410 


523 


688 


610 


653 


709 


449 


345 


315 


585 


566 


412 


6264 


1962 


386 


447 


672 


499 


652 


694 


611 


324 


316 


586 


632 


429 


6247 


1963 


693 


664 


702 


695 


457 


547 


556 


384 


316 


586 


711 


530 


6841 


1964 


604 


664 


674 


718 


566 


622 


621 


322 


315 


585 


705 


378 


6775 


1965 


393 


615 


702 


718 


653 


599 


575 


384 


316 


586 


674 


530 


6745 


1966 


693 


664 


703 


718 


651 


528 


567 


323 


316 


586 


715 


573 


7037 


1967 


431 


664 


703 


718 


653 


566 


503 


384 


376 


586 


450 


687 


6720 


1968 


693 


664 


703 


718 


412 


469 


551 


323 


316 


586 


715 


473 


6624 


1969 


428 


658 


700 


718 


653 


593 


464 


384 


376 


357 


581 


687 


6600 


1970 


693 


664 


703 


718 


390 


477 


554 


374 


316 


586 


715 


532 


6723 


1971 


426 


664 


703 


718 


653 


713 


659 


384 


376 


586 


715 


549 


7147 


1972 


693 


664 


702 


718 


653 


550 


565 


323 


316 


586 


715 


611 


7098 


1973 


508 


664 


702 


718 


653 


698 


584 


384 


316 


586 


641 


530 


6984 


1974 


511 


664 


703 


718 


653 


702 


593 


384 


376 


473 


621 


687 


7085 


1975 


693 


664 


703 


718 


489 


539 


571 


384 


376 


586 


710 


658 


7091 


1976 


693 


664 


703 


565 


647 


550 


503 


324 


315 


506 


503 


289 


6261 


1977 


332 


582 


507 


473 


406 


199 


213 


189 


119 


110 


193 


194 


3517 


1978 


156 


312 


667 


717 


355 


389 


437 


384 


265 


426 


612 


530 


5250 


1979 


656 


642 


423 


718 


653 


713 


678 


384 


316 


586 


703 


578 


7051 


1980 


542 


664 


703 


718 


653 


568 


458 


384 


316 


435 


612 


530 


6582 


1981 


693 


664 


703 


718 


653 


538 


549 


323 


316 


586 


715 


452 


6910 


1982 


380 


664 


699 


718 


653 


706 


600 


384 


376 


479 


611 


687 


6957 


1983 


693 


664 


703 


704 


381 


342 


422 


384 


376 


586 


715 


687 


6657 


198A 


693 


511 


503 


279 


286 


435 


552 


384 


316 


586 


715 


634 


5895 


1985 


693 


664 


703 


718 


624 


536 


552 


323 


316 


586 


715 


484 


6916 


1986 


406 


590 


703 


712 


653 


615 


605 


384 


376 


460 


611 


575 


6690 


1987 


693 


425 


611 


705 


650 


713 


513 


322 


316 


586 


574 


384 


6494 


1988 


306 


445 


698 


705 


520 


454 


472 


321 


315 


584 


406 


342 


5570 


1989 


385 


434 


448 


522 


412 


710 


677 


322 


315 


585 


714 


686 


6211 


1990 


479 


393 


546 


680 


538 


520 


337 


322 


313 


504 


215 


306 


5154 



1991 284 381 421 406 407 688 530 382 313 479 272 361 4922 
AVG 500 577 638 680 590 594 553 356 323 525 600 499 6433 



2-28 



Difference in Total Delta Exports (Banks+North Bay Aqueduct+Tracy+Contra Costa Canal) (TAF) 
Existing Level of Demand; Preferred Alternative Minus No-Action; D-K85 100BW-100BH 



YEAR 


OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


TOTAL 


1922 





-3 


-1 


12 


-1 


6 


-5 





4 


12 


2 


1 


27 


1923 


-15 














8 


2 





7 


1 


1 





4 


1924 


1 





-1 











-8 


-5 


-4 


-9 


-10 


-9 


-45 


1925 

















6 








12 


12 


8 


9 


47 


1926 





-1 


-2 





8 


1 


-6 





7 


1 


1 





9 


1927 








1 





-1 





-5 





7 


1 


1 


1 


5 


1928 


1 

















-6 





7 


1 


1 





4 


1929 


1 


-2 


-2 











-8 





-1 


-7 


-5 





-24 


1930 


-17 


-8 








11 


6 


■2 





12 


13 


12 


4 


31 


1931 








-1 

















-1 











-2 


1932 








-1 


5 


-40 





-1 


-2 


12 


9 








-18 


1933 


-1 


-8 

















-1 





-7 








-17 


1934 





-1 


4 





-22 























-19 


1935 


























12 


12 


12 




40 


1936 


10 


-1 


-1 





-1 


5 


-5 





7 





2 


-4 


12 


1937 


1 


-2 


-1 





-1 


-3 


-5 





10 


1 






1 


1938 





-2 


2 





-2 


1 


-6 





7 









3 


1939 


1 

















-9 








-5 


-3 




-17 


1940 


-3 


-3 


-1 


-2 


-3 











12 


12 


13 




25 


1941 





-1 





-1 


■2 


-1 


-5 





6 


1 






-1 


1942 


1 

















-5 





7 


1 






4 


1943 


1 











2 





-5 





7 


2 






9 


1944 




















-5 





7 


1 







4 


1945 


-1 


-4 


5 








-1 


-6 





7 


1 




-1 


1 


1946 








1 








-1 


-5 





8 


1 




4 


9 


1947 


1 


-2 


-1 


4 








-5 





7 


1 


-2 





3 


1948 





-3 


-2 











-6 





12 


3 







5 


1949 


1 


-3 


2 





-1 


1 


-6 





7 


1 







2 


1950 





-2 


-2 


-2 


9 





-6 





7 


1 




-3 


3 


1951 


1 














-1 


-5 





7 


1 







4 


1952 











-2 


1 





•5 





7 







1 


4 


1953 


1 

















-5 


-6 





12 




1 


5 


1954 


-5 














6 


-5 





7 


1 




1 


6 


1955 





-5 











2 


-3 





7 


1 


-1 





1 


1956 





1 





-4 





5 


-10 








8 




-5 


-4 


1957 


1 














6 


-5 





7 


1 







11 


1958 


1 











-3 


-4 


-5 





6 







1 


-3 


1959 


1 





-1 





2 





-5 


-6 


1 


12 


2 





6 


1960 





1 


-2 








4 


-5 





8 


1 





1 


8 


1961 





-3 


-1 





4 





-5 


-6 





12 








1 


1962 





-4 


-2 





-2 


7 


-6 





10 





2 


1 


6 


1963 


1 








1 








-5 





6 





1 


1 


5 


1964 


3 














-1 


-7 





8 





3 





6 


1965 





-2 


5 











-5 





-1 


9 





2 


8 


1966 


1 

















-5 





8 





2 


1 


7 


1967 





-1 





-2 








-6 





6 





1 


1 


-1 


1968 


1 

















-6 





7 


1 





1 


4 


1969 


1 


-1 


1 


-1 








-6 





7 








1 


2 


1970 


1 








■3 


1 


3 


-5 





8 





2 


1 


8 


1971 

















1 


-5 





-1 


9 


1 


1 


6 


1972 


1 

















-5 





8 





2 


1 


7 


1973 


1 











-2 


1 


-5 





7 





1 


1 


4 


1974 


1 

















-5 





-1 


9 


1 


1 


6 


1975 


1 

















-5 





7 





1 


-1 


3 


1976 


1 














2 


-8 


-6 


-1 


-9 


-4 


-1 


-26 


1977 


-8 


-5 


-4 


























7 


-10 


1978 





-7 























12 


12 


12 


29 


1979 


-21 


-9 


42 


-1 


-1 


7 


-5 





12 


1 


2 





27 


1980 


-6 





2 








6 


-6 








8 


1 


1 


6 


1981 


1 

















-6 





8 


1 


1 





5 


1982 








1 








-2 


-5 





8 





2 


1 


5 


1983 


1 

















-5 





6 


1 


1 


1 


5 


1984 


1 


-2 


2 











-5 





8 


1 


1 


-2 


4 


1985 


1 











3 





-5 





8 


1 


1 





9 


1986 


1 


-3 





5 


-3 


2 


-5 








7 


2 


1 


7 


1987 


1 


-2 


2 


1 





5 


-6 


-5 


-4 


-3 


-8 


1 


-18 


1988 


-3 


-5 


-1 


2 


13 


5 


-5 


1 


-3 


-9 


-10 





-15 


1989 


1 


1 


1 


1 


3 


6 








12 


12 


13 


12 


62 


1990 


4 





-1 











-10 








-4 


-4 


-9 


-24 


1991 


-1 


-22 


-7 





-1 














4 








-27 



AVG 



-0 



-2 



-5 



-1 



2-29 



Total Delta Exports (Banks*North Bay Aqueduct*Tracy*Contra Costa Canal) (TAF) ^^^ 

Existing Level of Demand, No-Action; 0- U85*NMfS+USFUS OCAP BO 

YEAR OCT NOV DEC JAN FEB MAR APR MAT JUN JUL AUG SEP TOTAL 

1922 408 435 702 718 653 713 317 7 302 398 5V^ o 

1923 693 664 703 718 569 306 317 171 272 398 545 68/ 6UO 

1924 574 466 626 576 285 192 179 266 280 353 325 232 4356 

1925 264 424 560 497 652 343 316 170 27 397 553 686 5134 

1926 433 428 456 646 589 264 262 266 301 368 514 685 5212 

1927 512 662 698 589 652 593 317 171 272 398 586 687 6 38 

1928 677 664 702 525 505 713 317 171 272 398 554 686 6182 

1929 538 515 570 604 338 274 203 282 210 282 32 340 4468 

1930 353 363 614 490 338 506 262 283 195 303 519 352 4579 

1931 334 305 317 599 304 231 202 283 211 259 20 299 3 46 

1932 319 347 700 705 611 235 246 284 301 385 521 492 5147 

1933 338 399 432 656 292 288 238 282 247 341 519 378 4412 

1934 300 291 620 705 405 247 205 282 121 94 305 347 3922 

1935 258 471 447 622 321 624 317 171 272 398 568 687 5155 

1936 673 481 530 718 653 548 316 171 272 398 566 686 6012 

1937 608 440 504 696 653 687 317 171 272 398 554 687 5985 
938 652 515 702 718 653 670 441 291 302 398 6 687 6651 

1939 693 664 687 678 403 312 223 282 286 358 25 687 5799 

1940 444 383 480 684 647 667 464 171 272 398 578 687 5875 

1941 663 523 703 718 653 661 464 171 302 398 622 687 6565 

1942 693 664 703 718 653 512 356 171 302 398 617 687 6474 

1943 693 664 651 718 653 713 317 171 272 398 83 687 6522 

1944 693 577 614 662 621 415 226 284 302 371 523 672 5960 

1945 404 663 702 705 639 559 297 171 272 398 554 686 6051 

1946 632 663 702 718 497 443 317 171 272 398 559 687 6060 

1947 504 526 703 584 418 358 233 266 301 369 506 637 5407 

1948 434 466 427 574 218 340 316 170 301 397 535 686 4867 

1949 693 594 582 541 286 709 262 283 301 369 508 573 5700 

1950 424 447 428 534 559 387 316 171 272 397 530 686 5153 

1951 693 663 702 718 604 520 317 171 272 398 564 687 6310 

1952 623 664 703 718 653 592 441 291 302 398 615 687 6686 

1953 693 664 703 718 506 388 317 171 295 398 556 687 6095 

1954 693 664 617 514 636 648 317 171 272 398 538 687 6156 

1955 693 642 543 620 308 271 222 284 301 364 511 686 5445 

1956 464 491 702 718 599 554 317 171 302 398 564 687 5968 

1957 693 641 607 638 602 671 262 171 272 398 514 687 6157 

1958 693 664 544 718 653 713 464 171 302 398 581 687 6590 

1959 693 664 619 675 653 327 216 284 302 358 505 687 5984 

1960 553 429 489 567 475 394 196 170 271 379 501 685 5110 

1961 481 510 689 581 426 315 199 282 300 358 491 577 5211 

1962 375 438 640 502 652 366 245 171 272 397 499 594 5151 

1963 693 663 532 484 525 501 464 171 272 398 549 687 5939 

1964 693 561 636 539 253 222 204 283 301 359 494 685 5232 

1965 369 588 702 717 546 385 317 171 272 398 605 687 5758 

1966 693 664 703 718 545 395 275 171 272 375 517 687 6015 

1967 626 664 703 718 620 581 376 291 302 398 578 687 6544 

1968 693 664 703 602 653 539 249 171 272 373 536 687 6142 

1969 538 594 525 718 653 645 317 291 302 398 580 687 6250 

1970 693 664 703 718 653 605 276 171 272 398 550 687 6390 

1971 645 586 703 718 442 704 317 171 302 398 555 687 6228 

1972 693 624 702 703 416 460 241 171 272 369 504 687 5844 

1973 693 664 563 718 653 712 317 171 272 398 551 687 6400 

1974 693 664 703 718 653 713 464 171 302 398 560 687 6727 

1975 693 664 703 663 653 713 317 171 302 398 553 687 6517 

1976 693 664 703 523 274 260 181 267 280 330 492 454 5120 

1977 296 347 406 416 149 186 192 281 170 91 273 210 3016 

1978 156 180 579 717 622 464 317 171 272 398 572 687 5135 

1979 693 639 493 642 653 713 317 171 272 362 520 687 6165 

1980 693 664 703 718 653 713 317 171 272 398 573 687 6563 

1981 693 664 703 555 457 573 257 268 302 361 518 687 6038 

1982 534 595 699 718 653 658 441 291 302 398 667 687 6643 

1983 693 664 703 718 653 440 435 291 302 398 715 687 6700 

1984 693 602 508 453 340 460 317 171 272 398 605 687 5507 

1985 693 664 703 694 437 443 263 268 302 366 523 687 6043 

1986 527 530 703 508 653 571 317 171 302 398 610 687 5978 

1987 693 572 599 554 335 467 229 275 286 359 526 518 5413 

1988 270 308 656 492 169 173 189 282 279 339 504 475 4136 

1989 341 390 420 482 148 664 262 266 301 368 515 584 4742 

1990 410 296 389 603 224 232 196 281 276 335 501 445 4188 

1991 296 277 325 391 149 452 226 282 290 363 498 441 3991 

AVG 558 545 610 632 505 485 295 220 279 371 531 623 5652 



2-30 



Difference in Total Delta Exports (Banks+North Bay Aqueduct+Tracy+Contra Costa Canal) (TAF) 
Existing Level of Demand, Preferred Alternative Minus No-Action; D- 1485+NMFS+USFUS OCAP BO 167E-167t) 



YEAR 


OCT 


NOV 


DEC 


JAN 


FEB 


1922 





-2 





12 


-1 


1923 


11 














1924 


1 














1925 


-20 


-5 











1926 


11 











-1 


1927 








-1 








1928 


-5 














1929 

















1930 


-22 


-7 


9 








1931 

















1932 


-4 














1933 


12 











-2 


1934 








5 








1935 














1 


1936 


10 


11 








-2 


1937 


10 


2 








-2 


1938 


9 


-5 








-2 


1939 


10 





-1 








1940 


4 











-4 


1941 


12 


8 





-2 


-3 


1942 


1 














1943 


1 





-1 








1944 


1 














1945 








13 





9 


1946 

















1947 


13 














1948 

















1949 


12 


-8 


-1 








1950 








-2 








1951 


7 


1 








-17 


1952 


1 








-2 


2 


1953 


10 














1954 


10 








-2 





1955 


1 


-1 











1956 











-5 


-1 


1957 


13 














1958 


1 











-3 


1959 


1 














1960 








1 








1961 


2 


-2 


-1 








1962 





-3 


1 





-3 


1963 


10 








-1 


1 


1964 


3 














1965 


3 





12 


7 





1966 


4 














1967 


5 








-2 





1968 


9 














1969 


1 








-1 





1970 


10 








-3 


2 


1971 


-5 














1972 


1 














1973 


1 











-2 


1974 


4 














1975 


6 














1976 


1 














1977 





-6 


-7 


-6 





1978 














-8 


1979 


13 





-16 


1 





1980 





12 


12 








1981 


3 














1982 


1 





11 








1983 


1 














1984 


1 


-1 


1 








1985 


1 














1986 





-3 








■3 


1987 


7 


-4 











1988 





-2 











1989 





-7 





1 





1990 


12 


1 











1991 





-1 












MAR APR MAY 

6 















-5 

2 -7 -3 



-4 -2 

-1 -4 



















42 

-7 -3 











-2 -4 









0-4 







0-3 



0-3 

-13 





1 
1 -4 





7 


-2 
-2 -7 

1 -5 


6 




1 





JUN JUL AUG 





-24 









-16 







-30 22 -4 

0-2 









1 























































































8 







0-1 











SEP 


TOTAL 


12 


27 


10 


21 





-23 


12 


-13 





10 


12 


11 


3 


-2 


-1 


-17 


-4 


-24 








11 


7 


-21 


-23 





3 


12 


13 


12 


31 


11 


16 


12 


6 


-3 


7 


12 


6 


9 


19 


9 


10 


3 


3 


3 


4 


12 


34 


12 


12 





13 


12 


12 





3 


12 


10 


12 


45 


12 


3 


12 


22 


3 


11 








12 


6 


9 


22 


8 








1 


10 


11 





-1 


10 


5 


12 


18 





3 


12 


34 


11 


15 


12 


12 


3 


12 


12 


9 


10 


6 


10 


5 


10 


11 


12 


12 


12 


13 


9 


15 


-22 


-21 





-19 


12 


4 





5 


12 


36 





1 


10 


13 


1 


6 


11 


12 





1 


12 


12 





2 





-2 


10 


5 





13 





-1 



AVG 



-0 



-1 



1 



-1 



-0 



-1 



2-31 



Change in CVP EOM Storage 

Relative to No-Action Case 

Existing Demands, D1485 and D1485 with OCAP BO 

Average CVP End-of-Month Storage (TAF) 



6 
5 
4 
3 
2 
1 

■1 
-2 



□ d1485 ■D1485 + OCAP BO 




Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep 

Month (1922-1991) 



CCWD rad 09/15/93 



2-32 



Total End-of-Month Storage in CVP Reservoirs (TAF) 

(Ctair Engle, Whiskeytown, Shasta, Keswick, Folsom, San Luis) 

Existing Level of Demand, No-Action; D-U85 lOObH 



YEAR 


OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


1922 


5616 


5726 


6064 


6366 


6877 


7515 


8413 


8812 


8402 


7505 


6671 


6481 


1923 


6389 


6195 


6380 


6789 


7119 


7489 


8167 


7977 


7270 


6200 


5269 


5114 


1924 


5106 


5094 


5040 


5226 


5629 


5616 


5318 


4821 


4151 


3355 


2774 


2588 


1925 


2617 


2820 


3131 


3546 


5615 


6259 


7475 


7653 


6859 


5677 


4766 


4610 


1926 


4550 


4613 


4696 


4913 


6129 


6644 


7430 


7049 


6069 


4881 


3915 


3681 


1927 


3657 


4560 


5442 


6242 


6399 


7448 


8153 


8379 


7972 


6945 


6056 


5852 


1928 


5844 


5981 


6166 


6676 


7388 


7547 


8436 


8401 


7433 


6182 


5210 


4988 


1929 


4895 


5033 


5153 


5392 


5804 


6210 


6274 


6155 


5773 


4855 


4186 


3999 


1930 


3930 


3876 


4785 


5270 


5997 


6873 


7251 


6948 


6049 


4816 


3778 


3596 


1931 


3500 


3518 


3467 


3781 


4053 


4375 


4240 


3938 


3491 


2832 


2363 


2240 


1932 


2199 


2244 


2816 


3349 


3700 


4311 


4465 


4733 


4225 


3127 


2307 


2092 


1933 


1949 


1881 


1883 


2192 


2446 


3256 


3646 


3832 


3761 


3142 


2665 


2568 


1934 


2549 


2560 


2922 


3564 


4205 


4774 


4943 


4667 


4187 


3530 


3054 


2918 


1935 


2878 


3206 


3454 


3966 


4426 


5132 


6509 


6902 


6310 


5143 


4159 


3903 


1936 


3852 


3846 


3840 


5064 


5842 


6531 


7176 


7119 


6708 


5558 


4571 


4334 


1937 


4184 


4080 


4106 


4258 


4662 


5587 


6764 


7229 


6910 


5835 


4917 


4696 


1938 


4699 


5146 


5471 


6078 


6282 


6484 


7593 


8522 


8495 


7849 


7085 


6709 


1939 


6255 


6068 


6267 


6580 


6850 


7562 


7411 


6915 


6082 


4949 


3994 


3776 


1940 


3657 


3494 


3573 


5175 


6327 


6948 


8207 


8394 


7586 


6406 


5435 


5257 


1941 


5279 


5394 


6247 


6644 


7157 


8180 


8975 


9167 


8942 


8162 


7401 


7223 


1942 


6880 


6575 


6781 


7064 


7419 


8105 


8949 


9120 


8895 


8054 


7267 


7115 


1943 


6747 


6571 


6654 


7093 


7666 


8223 


8988 


9047 


8406 


7306 


6442 


6249 


1944 


6281 


6406 


6454 


6727 


7256 


7866 


7865 


7761 


7102 


5967 


5028 


4815 


1945 


4747 


5184 


5734 


6198 


7344 


7931 


8356 


8439 


7831 


6710 


5788 


5560 


1946 


5690 


6033 


6287 


6934 


7448 


8135 


8653 


8687 


7877 


6728 


5795 


5618 


1947 


5542 


5814 


6066 


6262 


6762 


7626 


7889 


7311 


6705 


5556 


4633 


4412 


1948 


4522 


4678 


4693 


5689 


5911 


6287 


7839 


8388 


8217 


7232 


6287 


6098 


1949 


6057 


6047 


6186 


6364 


6744 


7616 


8270 


8414 


7623 


6466 


5556 


5369 


1950 


5247 


5275 


5254 


5930 


6564 


7342 


7986 


7920 


7244 


6217 


5374 


5207 


1951 


5543 


6093 


6476 


7027 


7592 


8353 


8750 


8935 


8231 


7040 


6138 


6006 


1952 


6077 


6377 


6611 


7127 


7594 


8124 


8809 


9184 


8998 


8466 


7807 


7415 


1953 


6897 


6690 


6757 


7155 


7742 


8458 


8970 


9052 


8738 


7985 


7203 


7099 


1954 


6799 


6582 


6669 


7094 


7507 


8303 


9041 


8996 


8192 


7048 


6253 


6133 


1955 


6168 


6381 


6645 


7003 


7346 


7616 


7718 


7815 


7099 


5961 


5054 


4909 


1956 


4814 


4941 


6377 


6871 


7144 


8172 


9067 


9167 


8942 


8159 


7437 


7137 


1957 


6752 


6555 


6668 


6954 


7430 


8219 


8589 


8986 


8510 


7546 


6750 


6654 


1958 


6640 


6575 


6640 


7143 


8784 


7765 


8692 


9167 


8981 


8371 


7702 


7303 


1959 


6819 


6583 


6675 


7287 


7615 


8377 


8522 


8260 


7473 


6374 


5487 


5433 


1960 


5346 


5233 


5180 


5631 


6908 


8001 


8155 


8121 


7375 


6204 


5223 


5040 


1961 


4952 


5165 


5756 


6178 


7283 


7950 


8155 


8086 


7509 


6336 


5415 


5246 


1962 


5123 


5204 


5628 


5948 


7135 


7975 


8581 


8437 


7842 


6716 


5863 


5716 


1963 


6429 


6278 


6599 


7003 


7796 


8274 


8556 


9071 


8575 


7593 


6772 


6665 


1964 


6567 


6582 


6671 


7242 


7642 


7850 


7665 


7345 


6734 


5598 


4680 


4504 


1965 


4407 


4734 


6558 


7048 


7759 


8245 


8870 


9058 


8511 


7538 


6886 


6781 


1966 


6633 


6556 


6677 


7284 


7820 


8354 


9005 


8952 


8109 


7039 


6161 


5969 


1967 


5846 


6374 


6665 


7149 


7815 


8150 


8847 


9184 


8966 


8475 


7801 


7410 


1968 


6931 


6723 


6815 


7301 


7569 


8406 


8530 


8293 


7460 


6347 


5692 


5551 


1969 


5572 


5800 


6421 


6818 


7202 


8066 


8908 


9184 


8998 


8487 


7762 


7352 


1970 


6890 


6705 


6869 


7448 


7646 


8580 


8578 


8514 


7877 


6848 


6034 


5895 


1971 


5922 


6529 


6624 


7197 


7817 


8070 


8930 


9051 


8737 


7980 


7215 


7029 


1972 


6722 


6549 


6663 


7275 


7812 


8576 


8875 


8720 


7902 


6809 


6013 


5875 


1973 


5934 


6346 


6651 


7169 


7476 


8286 


8956 


9144 


8282 


7149 


6360 


6244 


1974 


6418 


6765 


6949 


7367 


7896 


7765 


8803 


9179 


8993 


8368 


7685 


7284 


1975 


6794 


6591 


6688 


7031 


7677 


7830 


8859 


9052 


8763 


8079 


7411 


7128 


1976 


6777 


6575 


6670 


6932 


6924 


7362 


7419 


7182 


6545 


5605 


5014 


4922 


1977 


4882 


4786 


4646 


4687 


4650 


4589 


4309 


4053 


3520 


2880 


2497 


2504 


1978 


2461 


2526 


3346 


5792 


6441 


7234 


8121 


8397 


8162 


7168 


6345 


6343 


1979 


6116 


6001 


6033 


6407 


6958 


7837 


8250 


8494 


7727 


6728 


5966 


5792 


1980 


5916 


5958 


6192 


6742 


6946 


8027 


8775 


8962 


8394 


7583 


6787 


6749 


1981 


6487 


6294 


6510 


7117 


7749 


8238 


8605 


8172 


7282 


6160 


5302 


5123 


1982 


5162 


6346 


6618 


7173 


7359 


8074 


8613 


9184 


8998 


8389 


7719 


7327 


1983 


6846 


6649 


6761 


7131 


7286 


8281 


8593 


9184 


8998 


8616 


8089 


7804 


1984 


7319 


7098 


7384 


7713 


8004 


8485 


9008 


9058 


8611 


7645 


7041 


6914 


1985 


6613 


6575 


6658 


6988 


7390 


7877 


8230 


7741 


6798 


5730 


4859 


4739 


1986 


4690 


4779 


5170 


6259 


6980 


7726 


8508 


8672 


8115 


7093 


6267 


6304 


1987 


6349 


6408 


6509 


6799 


7422 


8305 


8312 


7789 


6826 


5642 


4724 


4522 


1988 


4384 


4393 


5239 


6059 


6400 


6526 


6530 


6208 


5564 


4386 


3524 


3298 


1989 


3150 


3436 


3602 


3916 


4112 


6376 


7293 


6974 


6123 


4962 


4139 


4065 



1990 4217 4463 4449 5012 5333 5854 5745 5655 5289 4295 3666 3519 

1991 3461 3447 3397 3450 3487 4383 4843 4796 4369 3832 3329 3192 

AVE 5331 5408 5673 6175 6707 7326 7846 7888 7338 6377 5583 5399 



2-33 



Change in End-of-Honth Storage in CVP Reservoirs (TAF) 
(Clair Engle, Uhiskeytown, Shasta, Keswick, Folsom, San Luis) 
Existing Level of Demand, No-Action; 0-U85 



YEAR 


OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


1922 





3 


4 


2 


1 


1 


1 








1923 











-1 











-1 


-7 


192-; 


-12 


-11 


-10 


-9 


-9 


-10 


-1 


5 


9 


1925 


43 


43 


43 


43 


42 


36 


38 


38 


26 


1926 


-17 


-16 


-15 


-15 


-15 


-14 


-10 


-10 


-17 


1927 


-20 


-20 


-20 


1 


1 


1 


1 


1 


-6 


1928 


-9 


1 


1 


1 


1 


1 


1 


1 


-6 


1929 


-10 


-9 


-6 


-6 


-5 


-6 


3 


3 


3 


1930 


38 


46 


46 


46 


46 


41 


42 


41 


30 


1931 


5 


6 


8 


8 


8 


8 


16 


19 


22 


1932 


54 


54 


54 


47 


7 


7 


8 


8 


8 


1933 


3 


7 


8 


7 


8 


8 


17 


17 


20 


1934 


30 


30 


29 


30 


7 


7 


7 


7 


7 


1935 


7 


7 


7 


7 


7 


7 


7 


8 


7 


1936 


-53 


-53 


-52 


-48 

















1937 


-3 


-3 


-2 


-1 


-1 


-1 


-1 


-1 


-10 


1938 


-12 


























1939 




















8 


8 


9 


1940 


21 


23 


25 


24 


2 


2 


2 


3 


-10 


1941 


-43 


-43 


1 


1 


1 


1 











1942 





























1943 


























-7 


1944 


-9 


-8 


-7 


-7 


•7 


-6 





1 


-7 


1945 


-8 


-8 


8 


7 





-1 


4 


5 


-3 


1946 


-5 


-1 


-1 


-1 


-1 


-1 


-1 


-1 


-8 


1947 


-14 


-10 


-6 


-7 


-7 


-7 


-2 


-1 


-9 


1948 


-10 


-7 


■5 


-3 


-4 


-3 


-4 


■2 


-3 


1949 


-6 


-3 


-1 


-1 


-1 


-3 


5 


4 


-2 


1950 


-4 


-2 


1 


-1 








-1 








1951 


-3 


-1 


-2 


-1 


-1 


-1 


-2 


-2 


-6 


1952 


-11 


-2 























1953 





























1954 


-8 























-8 


1955 


-11 


-3 


-3 











6 


6 


-1 


1956 


-3 


4 





-1 

















1957 


-1 

















9 


1 


-6 


1958 


-3 


























1959 




















7 


13 


12 


1960 


-5 


-5 


-2 


-3 


-2 


-2 


5 


4 


-3 


1961 


-6 


-2 


-1 


-1 








5 


11 


11 


1962 


-6 


-2 


1 


1 


1 


1 


9 


8 


-1 


1963 


1 


1 


2 


1 














■6 


1964 


-12 














1 


7 


8 


-1 


1965 


-2 


1 




















1 


1966 


-3 

















5 


5 


-2 


1967 


-6 


-5 


-1 


-1 

















1968 




















6 


5 


■2 


1969 


-5 


-3 


-3 




















1970 


-2 


-2 


-2 


-2 








6 


6 


-2 


1971 


-6 


























1972 


-3 

















7 


7 


-1 


1973 


-3 


-1 




















-8 


1974 


-12 


-2 


-1 




















1975 





























1976 




















12 


18 


19 


1977 


45 


52 


58 


58 


58 


58 


58 


58 


57 


1978 


56 


56 


56 


11 


11 


11 


12 


12 


11 


1979 


-1 


12 


12 


12 


11 


n 


11 


11 





1980 


7 


11 


12 


11 


12 


11 


11 


11 


11 


1981 


9 


11 


10 


11 


10 


11 


16 


17 


8 


1982 


6 


6 


6 


6 

















1983 





























1984 





























1985 


-1 

















6 


5 


-2 


1986 


-5 








-1 








-1 


-1 





1987 


-2 





-2 


-1 


-1 





5 


10 


13 


1988 


22 


27 


26 


26 


10 


5 


12 


n 


14 


1989 


31 


31 


28 


27 


24 


24 


24 


23 


12 


1990 


-36 


-36 


-36 


-36 


-36 


-36 


-27 


-27 


-27 


1991 


-3 


9 


19 


20 


20 


20 


20 


21 


20 



AVE 



-0.2 



2.6 



4.1 



3.7 



2.8 



2.6 



5.3 



5.6 



2.3 



lOObW-IOObH 

JUL AUG SEP 

-19 -21 -21 

-9 -10 -11 

18 28 43 

8 -2 -17 

-19 -20 -20 

-7 -8 -9 

-7 -9 -9 

12 21 29 

13 14 6 
28 37 47 
-1 -1 -1 
28 31 31 

7 7 7 

-11 -26 -38 

-2 -3 

-11 -13 -12 

-1 -2 -1 

15 17 18 

-27 -43 -43 

-1 -2 

-1 -2 -1 

-8 -10 -10 

-8 -9 -9 

-4 -5 -6 

-10 -11 -13 

-9 -10 -11 

-4 -5 -6 

-4 -4 -4 

-2 -3 -2 

-8 -9 -10 



-13 -14 -14 

-9 -10 -10 

-2 -3 -3 

-8 -9 -2 

-7 -9 -9 



-4 -5 -4 

-5 -5 -6 

-4 -5 -5 

-1 -4 -5 

-5 -7 -9 

-1 -2 -2 

-8 -7 -10 

-2 -4 -6 



-3 -4 -5 

-2 -2 

-2 -4 -5 

-9 -10 -3 

-3 -3 

-7 -9 -11 



-1 -1 

31 35 38 

57 56 56 

-1 -17 -31 

-3 -4 -4 

3 3 3 

7 5 5 





-2 -3 

-4 -5 -5 

-1 -2 -2 

17 20 19 
22 31 32 
-5 -18 -31 

-21 -17 -13 

18 18 18 

-0.2 -1.2 -1.5 



2-34 



Total End-of-Month Storage in CVP Reservoirs (TAF) 

(Clair Engle, Whiskeytown, Shasta, Keswick, Folsom, San Luis) 

Existing Level of Demand, No-Action; D- KSS-'NMFS+USFWS CVP-OCAP BO 167D 



YEAR 


OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


1922 


5616 


5743 


6081 


6375 


6885 


7464 


8239 


8575 


8122 


7281 


6705 


6500 


1923 


6205 


6005 


6189 


6598 


6915 


7160 


7789 


7582 


6952 


6121 


5514 


5398 


1924 


5398 


5430 


5439 


5602 


5909 


5851 


5564 


5085 


4466 


3745 


3211 


3063 


1925 


3114 


3342 


3678 


4104 


6056 


6521 


7557 


7599 


6760 


5884 


5246 


4994 


1926 


4938 


5003 


5091 


5307 


6432 


6746 


7407 


7033 


6094 


5155 


4520 


4210 


1927 


4189 


5109 


5765 


6348 


6522 


7502 


8105 


8219 


7809 


6882 


6270 


6034 


1928 


5918 


6052 


6252 


6709 


7381 


7591 


8429 


8367 


7487 


6459 


5651 


5436 


1929 


5352 


5520 


5718 


5943 


6276 


6587 


6729 


6655 


6326 


5593 


5007 


4831 


1930 


4784 


4753 


5639 


5999 


6577 


7360 


7704 


7492 


6769 


5845 


5036 


4942 


1931 


4905 


4976 


5006 


5289 


5492 


5756 


5559 


5197 


4709 


4038 


3552 


3405 


1932 


3364 


3409 


3904 


4380 


4800 


5360 


5401 


5576 


5015 


4048 


3427 


3170 


1933 


3035 


2983 


3000 


3189 


3216 


4008 


4411 


4594 


4497 


3855 


3249 


3117 


1934 


3098 


3109 


3431 


4016 


4561 


5018 


5139 


4825 


4314 


3654 


3119 


2950 


1935 


2911 


3231 


3465 


4082 


4540 


5186 


6466 


6754 


6127 


5160 


4488 


4222 


1936 


4103 


4104 


4148 


5209 


5852 


6443 


6992 


6880 


6464 


5418 


4744 


4497 


1937 


4295 


4244 


4287 


4465 


4790 


5629 


6683 


7036 


6661 


5587 


4964 


4669 


1938 


4613 


5095 


5419 


6027 


6230 


6487 


7596 


8473 


8403 


7704 


6931 


6554 


1939 


6105 


5918 


6126 


6449 


6632 


7218 


7114 


6638 


5885 


5193 


4556 


4267 


1940 


4179 


4096 


4213 


5822 


6448 


7023 


8232 


8337 


7471 


6427 


5761 


5564 


1941 


5530 


5673 


6293 


6690 


7203 


8226 


8942 


9022 


8754 


7975 


7396 


7098 


1942 


6703 


6391 


6596 


6879 


7232 


7782 


8576 


8642 


8375 


7845 


7295 


7001 


1943 


6571 


6391 


6464 


6904 


7468 


8064 


8706 


8654 


8015 


7167 


6567 


6342 


1944 


6351 


6300 


6380 


6647 


7180 


7644 


7652 


7534 


6903 


6122 


5476 


5178 


1945 


5127 


5562 


6061 


6512 


7422 


7883 


8273 


8279 


7639 


6711 


6106 


5833 


1946 


5969 


6049 


6314 


6965 


7443 


8015 


8449 


8493 


7639 


6626 


6002 


5759 


1947 


5674 


5951 


6184 


6353 


6780 


7487 


7747 


7229 


6675 


5794 


5183 


4898 


1948 


5034 


5211 


5259 


6252 


6409 


6872 


7911 


8116 


7994 


7286 


6672 


6500 


1949 


6175 


5990 


6141 


6289 


6563 


7443 


8128 


8249 


7469 


6710 


6093 


5852 


1950 


5741 


5779 


5773 


6289 


6916 


7547 


8118 


8000 


7364 


6536 


5960 


5798 


1951 


6081 


6160 


6575 


7142 


7678 


8358 


8645 


8783 


8059 


7089 


6504 


6366 


1952 


6352 


6439 


6625 


7145 


7617 


8124 


8809 


9132 


8902 


8269 


7552 


7162 


1953 


6646 


6439 


6506 


6904 


7492 


8143 


8562 


8550 


8313 


7931 


7472 


7090 


1954 


6651 


6411 


6487 


6859 


7290 


8085 


8721 


8591 


7765 


7024 


6564 


6444 


1955 


6277 


6412 


6589 


6917 


7149 


7344 


7602 


7764 


7110 


6362 


5766 


5582 


1956 


5513 


5673 


6430 


6940 


7166 


8149 


8947 


8938 


8670 


7903 


7455 


7029 


1957 


6573 


6374 


6457 


6736 


7212 


8006 


8484 


8584 


8096 


7520 


7034 


6886 


1958 


6638 


6432 


6465 


6976 


8625 


7617 


8508 


8871 


8643 


7974 


7506 


7110 


1959 


6627 


6391 


6465 


7085 


7412 


8002 


8214 


7962 


7225 


6544 


5995 


5933 


1960 


5836 


5796 


5776 


6179 


7369 


7999 


8226 


8214 


7524 


6667 


6014 


5795 


1961 


5732 


5978 


6358 


6750 


7452 


7982 


8291 


8247 


7677 


6869 


6257 


6024 


1962 


5909 


5999 


6346 


6661 


7314 


7979 


8477 


8330 


7713 


6804 


6263 


6066 


1963 


6584 


6442 


6626 


6964 


7796 


8227 


8459 


8862 


8367 


7500 


7008 


6841 


1964 


6512 


6355 


6433 


6957 


7214 


7379 


7192 


6929 


6457 


5791 


5215 


5006 


1965 


4954 


5326 


6626 


7143 


7785 


8128 


8684 


8760 


8214 


7403 


7015 


6877 


1966 


6492 


6394 


6492 


7099 


7611 


8068 


8650 


8534 


7716 


7087 


6554 


6355 


1967 


6190 


6509 


6731 


7224 


7838 


8150 


8826 


9111 


8850 


8258 


7511 


7122 


1968 


6645 


6437 


6529 


6993 


7337 


8208 


8328 


8019 


7197 


6501 


6174 


6004 


1969 


6003 


6206 


6471 


6785 


7179 


8080 


8872 


9082 


8852 


8240 


7494 


7086 


1970 


6636 


6451 


6615 


7195 


7507 


8542 


8557 


8424 


7783 


6986 


6501 


6345 


1971 


6257 


6539 


6625 


7193 


7754 


8026 


8782 


8813 


8488 


7927 


7433 


7024 


1972 


6587 


6397 


6509 


7146 


7612 


8326 


8702 


8614 


7876 


7135 


6692 


6581 


1973 


6373 


6426 


6565 


7103 


7437 


8285 


8832 


8908 


8047 


6985 


6495 


6346 


1974 


6326 


6651 


6835 


7236 


7765 


7676 


8664 


8929 


8700 


7974 


7478 


7079 


1975 


6590 


6388 


6485 


6831 


7476 


7777 


8683 


8764 


8432 


7950 


7457 


7050 


1976 


6600 


6391 


6485 


6693 


6551 


6836 


7020 


6872 


6340 


5639 


5169 


5077 


1977 


5072 


5090 


5036 


5109 


5110 


5084 


4803 


4612 


4120 


3561 


3221 


3254 


1978 


3229 


3319 


4188 


5980 


6621 


7395 


8232 


8396 


8117 


7124 


6479 


6434 


1979 


6181 


6077 


6110 


6496 


7046 


7889 


8265 


8400 


7609 


6818 


6381 


6183 


1980 


5984 


5894 


6130 


6681 


6886 


8071 


8769 


8893 


8326 


7515 


6911 


6815 


1981 


6474 


6266 


6481 


7048 


7615 


8082 


8458 


8074 


7220 


6483 


5955 


5756 


1982 


5775 


6474 


6772 


7331 


7494 


8160 


8613 


9132 


8902 


8192 


7486 


7097 


1983 


6617 


6419 


6531 


6901 


7191 


8281 


8593 


9132 


8902 


8420 


7893 


7609 


1984 


7125 


6904 


7195 


7697 


8004 


8485 


8885 


8823 


8334 


7625 


7306 


6908 


1985 


6540 


6391 


6473 


6819 


7146 


7513 


7880 


7457 


6578 


5857 


5314 


5190 


1986 


5150 


5286 


5699 


6644 


7017 


7748 


8519 


8619 


8085 


7136 


6372 


6435 


1987 


6500 


6419 


6529 


6812 


7342 


8175 


8277 


7811 


6931 


5973 


5343 


5110 


1988 


5003 


5039 


5924 


6696 


7026 


7199 


7208 


6900 


6321 


5585 


4967 


4700 


1989 


4582 


4913 


5132 


5447 


5638 


7326 


8138 


7870 


7063 


6180 


5695 


5636 


1990 


5816 


6080 


6130 


6640 


6802 


7218 


7014 


6971 


6605 


5779 


5203 


4994 


1991 


4943 


4943 


4922 


4982 


4997 


5755 


6111 


6022 


5544 


4953 


4508 


4316 



AVE 5622 5662 5895 6369 6839 7396 7873 7869 7326 6548 5976 5754 



2-35 



Change in End-of-Month Storage in CVP Reservoirs (TAf) 

(Clair Engle, Uhiskeytown, Shasta, Keswick, Folsom, San Luis) 

Existing Level of Demand, No-Action; D- U85»NMFS*USFWS CVP-OCAP BO 

APR MAY JUN 

6 5 10 
5 5 5 

-4 2 4 

3 3 3 

-7 -7 -7 

3 3 -10 

7 8 1 
7 7 7 

11 11 -1 
-10 -9 -10 

1 1 1 
-3 -4 -3 

-14 -14 -14 

-11 -12 -23 

5 6 5 
-7 -1 1 

4 9 

16 16 16 

2 2 2 

4 4 3 

6 5 5 

4 3-4 

7 13 19 

6 10 17 

5 11 10 
-5 1 7 

5 5 5 

19 24 29 

8 8-4 
5 11 16 
4 10 

15 20 

5 4 -3 

7 13 18 

5 5 5 
-5 -5 -5 

3 4 3 

6 5 5 
5 6-6 

4 9 13 
4 4-7 

4 9 10 

5 10 2 
5 11 11 
5 11 10 

5 9 15 
19 20 12 

6 9 15 
5 5 5 
5 5 5 

5 5 6 

6 11 10 

4 3 10 
3 3 4 

9 9 14 
57 58 57 

12 12 12 
14 15 2 
12 12 17 
12 11 11 





5 5 5 

5 5 5 

6 5 5 
10 11 11 
12 12 12 

9 9 10 

-13 -13 -13 

-20 -20 -20 



YEAR 


OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


1922 





2 


2 


1 


1 


1 


1923 




















1924 


-12 


-12 


-12 


-12 


-13 


-12 


1925 


43 


50 


51 


51 


49 


49 


1926 


-20 


-19 


-19 


-19 


-12 


-12 


1927 


-12 


-11 


3 


5 


5 


3 


1928 


-2 


3 


2 


3 


2 


2 


1929 


-2 


-2 


-1 


■2 


-2 


-2 


1930 


44 


53 


30 


30 


30 


30 


1931 


-23 


■21 


-18 


-18 


-19 


-19 


1932 


6 


6 


6 


6 


2 


1 


1933 


-26 


-25 


-26 


-25 


-13 


-12 


1934 


2 


2 


-13 


-13 


-13 


-14 


1935 


•12 


-12 


-12 


-12 


-12 


-12 


1936 


-23 


-34 


-34 


-13 





1 


1937 


-24 


-26 


-26 


-25 


-11 


-12 


1938 


-37 


-3 


-2 


-3 


-2 





1939 


8 


8 


8 


8 


7 


7 


1940 


2 


3 


3 


6 


4 





1941 


-26 


-38 














1942 




















1943 








-1 


-1 





-2 


1944 


-1 


3 


2 


2 


2 


3 


1945 


-1 


-1 





-1 








1946 


-10 

















1947 


-17 


-17 


-10 


-11 


-11 


-10 


1948 


-10 


■10 


-10 


-10 


-10 


-10 


1949 


-2 


14 


13 


13 


13 


13 


1950 





-1 


3 


2 


2 


3 


1951 


-2 


17 


18 


17 








1952 


-3 


-1 














1953 


9 


9 


9 


9 


9 


10 


1954 











-1 


-1 


-1 


1955 


-1 


1 


2 


2 


2 


2 


1956 




















1957 





-10 


-10 


-10 


-10 


-10 


1958 




















1959 




















1960 











1 





1 


1961 


-9 


-7 


-2 


-2 


-2 


-2 


1962 


-1 


2 








1 





1963 




















1964 


-1 





-1 


-1 


-1 





1965 


5 


6 














1966 


-1 


-1 














1967 


-17 


-5 


-1 


-1 








1968 


15 


15 


15 


16 


15 


14 


1969 


-3 


-1 














1970 


15 


15 


15 


14 


13 





1971 


-6 


-1 


-1 











1972 




















1973 


-3 

















1974 


-6 


9 


10 


11 


11 





1975 

















-2 


1976 




















1977 


27 


33 


44 


49 


54 


58 


1978 


56 


56 


56 


20 


12 


12 


1979 


5 


25 


25 


21 


21 


20 


1980 


7 


7 


7 


7 


8 


7 


1981 


7 


7 


8 


7 


7 


6 


1982 


7 


7 


7 











1983 














-2 





1984 




















1985 




















1986 





3 


3 


2 








1987 


5 


5 


5 


6 


5 


2 


1988 


1 


4 


3 


3 


3 


4 


1989 


4 


11 , 


17 


19 


19 


9 


1990 


-21 


-20 


-20 


-22 


-22 


-22 


1991 


-20 


-20 


-20 


-20 


-20 


-21 



AVE 



-1.2 



1.1 



1.8 



1.6 



1.7 



1.2 



4.7 



6.2 



5.4 



167E-167D 

JUL AUG SEP 

-K 

-12 
4 23 33 
3 3 -7 

-12 -12 -11 

3 3 -12 

1 2 -1 

7 26 36 
-13 -13 -23 

-9 -1 6 

1 1 -14 

-19 -11 -3 

-14 -12 -11 

1 2 -13 

-15 

1 -13 -28 
10 9 9 

-1 3 

-14 

4 

0-3 

-10 
0-9 

-10 -10 -10 

-14 



2 1 -13 
-14 

10 10 10 



0-4 











0-9 

-1 -1 -1 

0-9 



6 

-14 

-13 

15 15 16 

0-3 

15 15 15 

-12 



-13 

-14 

110 



15 21 27 

57 56 56 

12 12 1 

8 9 8 
17 7 11 

7 7 7 





5 6 6 

8 2 1 

3 4 3 
0-9 

-21 -21 -21 

-20 -20 -20 

1.4 1.7 -2.0 



2-36 



Los Vaqueros Project Performance Matrix 

Scenario H40 

D-1485 water quality standards only. 
Existing level of development. 

Scenario H40 and its no action base case were based on Central 
Valley flows from DV^JRSIM run lOObH (existing level of 
development, D1485 base case with new hydrology 1922-1992) and 
the corresponding FDM 6E salinities. CCWD diversions from 
scenario H40 were incorporated in DWRSIM run lOObW to determine 
the effect of the Los Vaqueros project on Central Valley 
operations. Reservoir filling was limited according to the 
operations rules in the NMFS Los Vaqueros project biological 
opinion on winter run salmon and the 2 ppt limitations in 
the USFWS Los Vaqueros Project biological opinion for Delta smelt, 

Water Quality and Reliability Implications 



Average delivered chlorides (mg/1) 

■ Reservoir needed and failed goal 

■ Reservoir needed and met goal 

■ Reservoir not needed for blending 

Percentage of time water quality 
goal is met (< 65 mg/1 chlorides) 

Percentage of time blending water 
is not available from reservoir 





No 




H40 


Action 


Change 


106 


120 


-14 


65 






38 


36 


2 



94% 



10% 



62% 



100% 



32% 



-90% 



Percentage of April demands met from 
Los Vaqueros reservoir 



85% 



0% 



85% 



Reservoir storage probability: 
Less than or equal to 



4 TAP 

4 4 TAP 

5 5 TAP 

6 6 TAP 

7 5 TAP 

8 5 TAP 

9 5 TAP 



1% 


0% 


1% 


7% 


0% 


7% 


10% 


0% 


10% 


13% 


0% 


13% 


17% 


0% 


17% 


21% 


0% 


21% 


38% 


0% 


38% 



Average annual diversion for filling (TAP) 15.4 



0. 



15.4 



2-37 



Los Vaqueros Project Performance Matrix 

Scenario H50 

D-1485 with NMFS & USFWS CVP-OCAP biological opinions. 
Existing level of development. 

Scenario H50 and its no action base case were based on flows from 
DWRSIM run 167D (existing level of development, D1485 with NMFS 
and USFWS biological opinions for CVP-OCAP and 1922-1992 
hydrology) and the corresponding FDM 6K salinities. 167D was 
adapted from DWR's run 167B (D1485+NMFS only). CCWD diversions 
from scenario H50 were incorporated into DWRSIM run 167E to 
determine the effect of the Los Vaqueros project on Central Valley 
operations. Reservoir filling v/as limited according to operation 
rules in the NMFS Los Vaqueros Project biological opinion on 
winter run salmon and the 2 ppt limitations in the USFWS Los 
Vaqueros Project biological opinion for Delta smelt. 

QWEST standards in the NMFS and USFWS CVP-OCAP biological opinions 
place additional limitations on the availability of CVP 
rediversion water for filling the Los Vaqueros Reservoir. 
However, there is a corresponding improvement in water quality at 
the Rock Slough and Old River intakes. 



Water Quality and Reliabilitv Implications 



No 
H50 Action Change 



Average delivered chlorides (mg/1) 

■ Reservoir needed and failed goal 

■ Reservoir needed and met goal 

■ Reservoir not needed for blending 

Percentage of time water quality 
goal is met (< 65 mg/1 chlorides) 

Percentage of time blending v;ater 
is not available from reservoir 

Percentage of April demands met from 
Los Vaqueros reservoir 



88 
65 
41 

95% 



155 



83% 



111 
41 
65% 

100% 

0% 



-23 


30% 

-85% 
83% 



Reservoir storage probability: 
Less than or equal to 



4 TAF 

4 4 TAF 

55 TAF 

66 TAF 

7 5 TAF 

8 5 TAF 

9 5 TAF 



0% 


0% 


0% 


8% 


0% 


8% 


13% 


0% 


13% 


18% 


0% 


19% 


25% 


0% 


25% 


41% 


0% 


41% 


65% 


0% 


65% 



Average annual diversion for filling (TAF) 15.6 



0.0 



15.6 



2-38 



Reservoir Volume 

Existing Demands, D1485 



Reservoir Volume (TAF) 




22 26 30 34 38 42 46 50 54 58 62 66 70 74 78 82 86 90 

Water Year 



CCWD rad 09/01/93 



Reservoir Volume 

Existing Demands, D1485 + NMFS + USFWS OCAP BO 



Reservoir Volume (TAF) 




22 26 30 34 38 42 46 50 54 58 62 66 70 74 78 82 86 90 

Water Year 



CCWD rad 09/01/93 



2-39 



Delivered Chloride Concentration 

Existing Demands, D1485 

Delivered Chloride Concentration (mg/l) 




50% 55% 60% 65% 70% 75% 80% 85% 90% 95% 100% 

Cumulative Probability 



CCWD rad 09/01/93 



Delivered Chloride Concentration 
Existing Demands, D1485 + NMFS + USFWS OCAP BO 

Delivered Chloride Concentration (mg/l) 




50% 55% 60% 65% 70% 75% 80% 85% 90% 95% 100% 

Cumulative Probability 



CCWD rad 09/01/93 



2-40 



Differences Between Results Using 57 and 70 Year Hydrologies 



CCUO Diversions (TAF) 

Existing Level of Demand, No-Action, D-K85+NMFS+USFUS OCAP BO 



OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


TOTAL 


70 yr avg 10.90 


8.91 


7.49 


6.22 


5.06 


5.79 


5.90 


11.17 


13.34 


15.65 


16.36 


12.90 


119.82 


57 yr avg 10.88 


8.91 


7.46 


6.20 


5.02 


5.64 


5.80 


11.14 


13.39 


15.63 


16.47 


12.88 


119.41 


Diff:70-57 0.02 


0.01 


0.03 


0.02 


0.04 


0.15 


0.10 


0.03 


-0.05 


0.02 


-0.10 


0.02 


0.41 



Difference in CCUO Diversions (TAF) 

Existing Level of Demand, Preferred Alternative Minus No-Action, 



D-1485+NMFS+USFUS OCAP BO 





OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


TOTAL 


70 yr avg 


3.51 


0.22 


0.50 


-0.12 


-0.28 


0.09 


-4.92 


-1.58 


0.18 


0.18 


-0.73 


6.51 


3.55 


57 yr avg 


3.71 


0.27 


0.33 


-0.13 


-0.28 


-0.06 


-4.84 


-1.95 


0.09 


0.22 


-0.72 


6.98 


3.60 


Oiff:70-57 


-0.20 


-0.05 


0.17 


0.01 


0.00 


0.16 


-0.08 


0.36 


0.09 


-0.04 


-0.01 


-0.46 


-0.05 



Net Delta Outflow (TAF) 

Existing Level of Demand, No-Action, 



D-1485+NMFS+USFWS OCAP BO 





OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


TOTAL 


70 yr avg 


491 


657 


1372 


2240 


2722 


2501 


1571 


1184 


815 


455 


406 


380 


14795 


57 yr avg 


461 


566 


1238 


2220 


2545 


2227 


1490 


1185 


807 


440 


404 


363 


13947 


Diff:70-57 


30 


91 


134 


20 


177 


274 


81 


-1 


8 


15 


2 


17 


848 



Difference in Net Delta Outflow (TAF) 

Existing Level of Demand, Preferred Alternative Minus No-Action, D- 1485+NMFS+USFWS OCAP BO 





OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


TOTAL 


70 yr avg 


-2 


-2 


-2 


-1 


-0 


-1 


2 











-1 


-1 


-7 


57 yr avg 


-3 


-2 


-2 


-1 


-0 


-0 


2 











-1 


-1 


-8 


Diff:70-57 

















-0 


-0 


-0 





-0 


-0 


-0 


1 



QUEST (CFS) 

Existing Level of Demand, No-Action, D- 1485+NMFS+USFUS OCAP BO 



OCT 
70 yr avg -381 
57 yr avg -660 
Diff:70-57 279 



NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


-300 


694 


3225 


5904 


4913 


3863 


5873 


3385 


193 


-1827 


-2550 


-707 


-98 


2487 


4426 


3155 


2854 


5466 


3112 


-57 


-1837 


-2829 


407 


792 


738 


1477 


1758 


1009 


407 


273 


250 


10 


280 



Difference in QUEST (CFS) 

Existing Level of Demand, Preferred Alternative Minus No-action, D- 1485+NMFS+USFUS OCAP BO 





OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


70 yr avg 


-42 


-4 


-12 


-0 


9 


-9 


12 


4 


5 


-2 


3 


-76 


57 yr avg 


-44 


-5 


-11 


-1 


11 


-8 


11 


4 


6 


-2 


6 


-79 


Diff:70-57 


2 


1 


-1 





-2 


-1 


1 


-1 


-1 





-3 


4 



Total Delta Exports (TAF) 

Existing Level of Demand, No-Action, D- 1485+NMFS+USFUS OCAP 80 





OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


TOTAL 


70 yr avg 


558 


545 


610 


632 


505 


485 


295 


220 


279 


371 


531 


623 


5652 


57 yr avg 


558 


549 


616 


644 


523 


480 


296 


214 


276 


371 


525 


626 


5677 


Diff:70-57 


-0 


-4 


-6 


-12 


-18 


5 


-1 


6 


3 





6 


-3 


-25 



Difference in Delta Exports (TAF) 

Existing Level of Demand, Preferred Alternative Minus No-Action, D-1485+NMFS+USFUS OCAP BO 





OCT 


NOV 


DEC 


JAN 


FEB 


MAR 


APR 


MAY 


JUN 


JUL 


AUG 


SEP 


TOTAL 


70 yr avg 


3 


-0 


1 


-0 


-1 


1 


-1 


-0 


-0 





-1 


6 


8 


57 yr avg 


3 


-0 





-0 


-1 





-1 


-0 


-1 





-1 


6 


8 


Diff:70-57 





-0 














-0 








-0 





-0 






2-41 



Sacramento 4-River Index 

Source: California Department of Water Resources 
Sacramento 4-River Index (MAF) 




22 27 32 37 42 47 52 57 62 67 72 77 82 87 

Water Year (1922-1991) 



CCWD rad 09/01/93 



2-42 



Number of days meeting 2ppt salinity at Chipps Island. 

As per proposed EPA standard. 

Based on D1485+NMFS+USFWS OCAP BO and preferred alternative 

Assumes 2 ppt psu equals 3600 ^S/cm 





Cum 










Cum 










Prob 




Feb-Jun 


Reqd 




Prob 




Feb-Jun 


Reqd 


N 


% 


WYr 


Days 


Days 


N 


% 


WYr 


Days 


Days 


Wet 










Below Normal 






1 


4 


1927 


150 ( 


147) 


1 


8 


1932 


60 


(118) * 


2 


8 


1938 


150 ( 


147) 


2 


15 


1960 


90 


(118)* 


3 


12 


1941 


150 ( 


147) 


3 


23 


1989 


92 


(118) * 


4 


16 


1942 


150 ( 


147) 


4 


31 


1930 


120 


(118) 


5 


20 


1943 


150 ( 


147) 


5 


39 


1966 


120 


(118) 


6 


24 


1951 


150 ( 


147) 


6 


46 


1968 


121 


(118) 


7 


28 


1953 


150 ( 


147) 


7 


54 


1972 


121 


(118) 


8 


32 


1958 


150 ( 


147) 


8 


62 


1923 


150 


(118) 


9 


36 


1963 


150 ( 


147) 


9 


69 


1937 


150 


(118) 


10 


40 


1965 


150 ( 


147) 


10 


77 


1945 


150 


(118) 


11 


44 


1967 


150 ( 


147) 


11 


85 


1950 


150 


(118) 


12 


48 


1969 


150 ( 


147) 


12 


92 


1957 


150 


(118) 


13 


52 


1970 


150 ( 


147) 


13 


100 


1962 


150 


(118) 


14 


56 


1971 


150 ( 


147) 












15 


60 


1973 


150 ( 


147) 


Dry 










16 


64 


1974 


150 


147) 


1 


9 


1955 


59 


(114)* 


17 


68 


1978 


150 


147) 


2 


18 


1964 


60 


(114)* 


18 


72 


1982 


150 


147) 


3 


27 


1947 


89 


(114)* 


19 


76 


1983 


150 


147) 


4 


36 


1959 


89 


(114) * 


20 


80 


1986 


150 


147) 


5 


46 


1961 


89 


(114) * 


21 


84 


1940 


151 


147) 


6 


55 


1981 


89 


(114)* 


22 


88 


1952 


151 


147) 


7 


64 


1985 


89 


(114)* 


23 


92 


1956 


151 


147) 


8 


73 


1944 


90 


(114)* 


24 


96 


1980 


151 


'147) 


9 


82 


1949 


92 


(114)* 


25 


100 


1984 


151 


'147) 


10 


91 


1926 


120 


(114) 












11 


100 


1979 


150 


(114) 


Above Normal 
















1 


11 


1948 


122 


'141)* 


Critical 








2 


22 


1922 


150 


(141) 


1 


8 


1931 





( 80) * 


3 


33 


1925 


150 


(141) 


2 


17 


1977 





( 80)* 


4 


44 


1935 


150 


(141) 


3 


25 


1924 


29 


( 80)* 


5 


56 


1946 


150 


(141) 


4 


33 


1988 


29 


( 80)* 


6 


67 


1954 


150 


(141) 


5 


42 


1939 


31 


( 80)* 


7 


78 


1975 


150 


(141) 


6 


50 


1929 


59 


( 80)* 


8 


89 


1928 


151 


(141) 


7 


58 


1933 


59 


( 80) * 


9 


100 


1936 


151 


(141) 


8 


67 


1934 


59 


( 80) * 












9 


75 


1990 


59 


( 80)* 












10 


83 


1991 


61 


( 80)* 












11 


92 


1987 


89 


( 80) 












12 


100 


1976 


90 


( 80) 



2-43 



2-44 



Attachment 3. Additional Cultural Resources Information 



3-1 



3-2 



TABLE OF CONTENTS 

Page 

Letters from the Office of Historic Preservation 3-3 

Programmatic Agreement 3-6 

Cultural Resources Background Information 3-15 




STATE OF CAUFORWU — THE RESOURCES AGENCY PETE WILSOH, Co vmcf 

OFFICE OF HISTORIC PRESERVATION 
iJ^PARTMENT OF PARKS AND RECREATION 

P.O. BOX 042996 
SACRAMEMTO 94296-OOOt 
(SIS) a&3^624 
FAX: (»t6} 653-9624 

September 9, 1992 

REPLY TO: BUR910227A 

Susan E. Hoffman, Chief 

Division of Planning and Technical Services 

Bureau of Reclamation 

Mid-Pacific Regional Office 

2800 Cottage Way 

SACRAMH/ro CA, 95825-1898 

Project: Request for Determination of Eligibility and Effect for the Los 
Vaqueros Project, Oontra Costa County (Cultural Resources) 

Dear Ms. Hoffman: 

Ihcink you for requesting my views on the cited undertaking. Beised on 
staff review of the documentation you sutniitted, I would like to offer the 
following ocninents on the actions you have taken to oorply with Section 106 
of the National Historic Preservation Act. 

Your letter of Ai^ust 12, 1992, indicates that you have determined the 
Starr Ranch rivited buildings to be eligible for the National Register of 
Historic Places (NRHP) under criteria b and c. I concur with your 
determination that the Starr Ranch rivited buildings are eligible for the 
NRHP. 

Ihe Progranmatic Agreement (PA) that has been developed by the Bureau 
of Reclamaticn requires a Historic Property Treatment Plan (HFTP) that 
outlines the treatment for each eligible property within the Area of 
Potential Effect for the Los Vaqueros project. The inplementation of the 
HPTP will resijlt in a DetermijTation of No Adverse Effect. I concur with 
your finding of No Adverse Effect with the inplementation of the PA. 

Sincerely, 

Steade R. Craigo, AIA, Acting 
State Historic Preservation Officer 

cc: Carol Gleichman, ACHP 
> Dana McGowan, Jones & Stokes Associates, Inc. 



3^ 



■>.1« 



PETE WILSON. Cov»mor 
STATE Of CALIFORNIA — RESOURCES AG ENCY ^^^_^__^___===========^==== 



DEPARTMENT OF PARKS AND RECREATION 

P O BOX 942896 
\CRAWEMTO 94296 0001 




July 21, 1992 

REPLY TO: BLIR910227A2 

Susan E. Hoffman, Oiief 

Division of Planning and Technical Ser-vices 

Bureau of Reclamation 

Mid-Pacific Regional Office 

2800 Cottage Way 

SAO^AMHTTO CA 95825-1898 

Project: Request for Determination of Eligibility cind Effect for the Los 
Vaqueros Project, Contra Costa County (Cultural Resources) 

De^lr Ms. Hoffmcin: 

■Hiajik you for request irjg my views on the cited undertaking. Based on 
staff review of the documentation you sutmitted, I would like to offer the 
following comrnsnts on the actions you have taken to conply with Section 106 
of the National Historic Preservation Act. 

The reports indicate that reasonable measures were taken to identify 
historic properties within the project's APE. While it is seldcsn possible 
to guarantee that all cultural resources have been discovered during a 
survey, your inventory methods cire consistent with the Secretary of the 
Interior's Standards for Identification and satisfy us that you have 
fulfilled the requirements of 36 CFR 800. 4(a and b) . 

Ihe information presented to justify consideration of the sites as 
districts within the project curea seems well founded. IViis allows a 
consistent set of criteria and research questions to be applied to the 
properties throughout the project area. IViis consistency allows the 
research questions to be more focused on the relationship of the sites to 
each other while maintaining the ability to contrast this to neighboring 
areas. 

I concur with your findings of eligibility as listed in Table 2 of the 
report titled, "Evaluation, Request for Determination of Eligibility, and 
Effect for the Los Vaqueros Project, Alemeda and Contra Costa Counties, 
California". I also concur with the Bureau of Reclamation's finding that 
the Contra Costa Canal is not eligible for the National Register of Historic 
Places (NRHP) . 

You state that you are unsure of the historical significance of the 
Starr Ranch rivited buildings, which the consultants recanmended for 




Susan Hoffman 
July 21, 1992 
Page two 



eligibility to the NRltP under criterion d. You may want to consider the 
uniqueness of the use of this type of construction technology in a rural 
agricultural setting. Ihe eligibility of the reuxii mi^t be considered 
under criterion c as a 1930s rural carplex associated with Oscar Starr. 

Other factors that should be considered with the Starr ranch ccnplex is 
the fact that the ranch wcis used as a site for developing and testing the 
agricultural tractor technology that would later beooms associated with the 
Caterpiller Tractor Carpany. The fact that Steirr was a founder of the 
Caterpiller, one of the world's foremost producers of agricultural eind ecurth 
moving equipnient is a key factor in considering the significar>ce. The 
significance is magnified because of Caterpi Heir's Bay Area origins. You 
may wish to consider eligibility of the ccnplex under criteria b. 

Please contact us when you have made a determination of eligibility for 
this property. Until you have resolved your position on the eligibility of 
this prcperty, I can not consider a determination of effect. I will be 
looking forward to continuing the consultation on this project. 

Sincerely, 



Steade R. Craigo, AIA, Acting 
State Historic Preservation Officer 



3-5 



PROGRAMMATIC AGREEMENT 
AMONG THE BUREAU OF RECLAMATION, 
CONTRA COSTA WATER DISTRICT, CALIFORNIA STATE HISTORIC 
PRESERVATION OFFICER, AND THE ADVISORY 
COUNCIL ON HISTORIC PRESERVATION 
REGARDING THE IMPLEMENTATION OF THE LOS VAQUEROS PROJECT 

V«7HEREAS, the Bureau of Reclamation (BOR) has determined that 
implementation of the Los Vaqueros Project (Project) may affect 
historic properties included in or eligible for inclusion in the 
National Register of Historic Places, and has consulted with the 
California State Historic Preseirvation Officer (SHPO) and the 
Advisory Council on Historic Preservation (Council) pursuant to 
Section 800.13 of the regulations (36 CFR Part 800) implementing 
Section 106 of the National Historic Preservation Act (16 USC 
470f ) ; and 

WHEREAS, The Los Vaqueros Project involves the construction of a 
reservoir, water conveyance system, recreation facilities, and 
the rerouting of roads and utilities. The project is to be 
constructed on non-Federal land and does not involve any Federal 
funds but requires Federal permits and contracts. The Project 
may affect historic properties through the construction of 
project components and the operation of facilities; and 

WHEREAS, The area of potential effects (APE) for this undertaking 
includes lands subject to effects from project construction and 
operation of facilities. This APE is delineated in Attachments 
1-4 and may be modified according to the terms specified in 
Stipulation 1; and 

WHEREAS, the Contra Costa Water District (CCWD) was consulted and 
has been invited to concur in this Programmatic Agreement (PA) ; 
and 

WHEREAS, the Corps of Engineers (COE) is a cooperating Federal 
Agency and has been invited to concur in this PA; and 

WHEREAS, the California State Water Resources Control Board 
(SWRCB) is a responsible agency for purposes of compliance with 
California Environmental Quality Act; eind 

WHEREAS, the scope and magnitude of effects to historic 
properties have not yet been determined because project 
evaluation studies remain to be completed within the APE; and 

WHEREAS, the definitions listed in 36 CFR Part 800.2 are 
applicable throughout this PA; 

NOW, THEREFORE, the BOR, COE, California SHPO, SWRCB, Council and 
CCWD agree that the Los Vaqueros Project shall be administered in 

3-6 



accordance with the following stipulations to satisfy BOR's 
Section 106 responsibility for all individual aspects of the 
project. 

STIPULATION^ 

BOR will ensure that the following measures will be carried out: 

1. DEFINITION OF THE PROJECT AND ASSIGNMENT OF RESPONSIBILITY 

The project is defined in CCWD and BOR's joint Los Vaqueros 
Project Stage 2 EIR/EIS as the Los Vaqueros reservoir alternative 
(1992) . The BOR is designated lead federal agency (DL) for the 
implementation of this agreement, with the COE, CCWD, and SWRCB 
as responsible/cooperating parties. 

A. If the nature of the Project changes, the BOR will 
consult with the SHPO, CCWD, SWRCB, and the COE in a timely 
manner to determine the need for modification of the APE and 
scope of historic property identification, evaluation, and 
treatment measures defined in Stipulations 2-4 below. The 
Council will be notified of any agreed upon changes before those 
changes cause any effect to historic properties, and any 
objections raised by Council will be considered in further 
consultation. If agreement cannot be reached about the scope of 
these modifications, the BOR shall consult the Council pursuant 
to Stipulation 12. 

B. In the event that a change in the DL is proposed, the 
BOR will immediately notify the other parties to this agreement 
and an amendment to the PA will be initiated through the process 
indentified in Stipulation 11. 

2. INVENTORY OF HISTORIC PROPERTIES 

The BOR will consult with the SHPO to review historic property 
identification studies already conducted in the Project's APE and 
determine the scope and extent of further actions needed to 
complete the inventory. The BOR shall then ensure that the 
necessary actions are taken to complete the historic property 
inventory of the APE in a manner consistent with the Secretary of 
the Interior Standards and Guidelines for Identification (48 FR 
44720-23) , the National Peurk Service publication The 
Archaeological Survey: Methods and Uses (1978: GPO Stock No. 
024-016-00091) , and guidance offered by the SHPO. 

The BOR will ensure that archaeological properties identified 
during the inventory are recorded or updated on California 
Department of Parks amd Recreation Form 422 in accordaince with 
the Office of Historic Preservation's (OHP) guidelines California 
Archaeological Handbook for Completing an Archaeological Site 
Record (March 1989) smd that those forms have been submitted and 



3-7 



permanent site numbers have been assigned by the ^PP^J^^^J^ 
Information Center of the California Archaeological Inventory 
prior to the submission of inventory reports for review. 
Historic resources located during the inventory shall be recorded 
on DPR Form 52 3 in accordance with the OHP's Instructions for 
completing California Historic Resources I nventory Forms (March 
1984) . 

The BOR shall ensure that reports are prepared and circulated for 
review in accordance with the provisions contained in Stipulation 
6 prior to taking any action that might affect historic 
properties. 

3 . HISTORIC PROPERTY EVALUATION 

The BOR will consult with the SHPO and the cooperating agencies 
to determine the scope and timing of the studies needed for 
purposes of evaluating the National Register of Historic Places 
(NRHP) eligibility of cultural resources in the APE prior to 
initiating any activities that might affect historic properties. 

The BOR will ensure that all cultural resources affected by the 
Project are evaluated to determine their eligibility for 
inclusion in the NRHP in consultation with the SHPO and the 
responsible/cooperating agencies, taking into account the 
Secretary of Interior's Standards and Guidelines for E valuation 
(48 FR 190:44729-44738), National Register Bulletin 15: How to 
Applv the National Register Criteria fo r Evaluation (1991), 
Guidelines for Archaeological Research Designs (Office of 
Historic Preservation 1991) , and other guidance offered by the 
SHPO. All evaluations will be directed by a research design. 

Once evaluation studies have been initiated, the BOR will ensure 
that data recovered are fully analyzed and dociimented according 
to the research design that was prepeored to guide the evaluation. 
Changes in the Project will not relieve the BOR from the 
responsibility to ensure completion of resource evaluations once 
data have been collected or cultural materials have been removed 
from an archaeological site. 

By mutual agreement among the BOR, COE, SWRCB, 2md the SHPO, 
evaluation studies will be completed amd be addressed in a 
Determination of Eligibility report. The BOR shall ensure that 
the evaluation study or studies aire prepeared and submitted for 
review according to the provisions of Stipulation 6. No further 
consideration need be given properties the BOR, SHPO, emd the 
responsible/cooperating agencies agree are not eligible for 
inclusion in the NRHP. If an evaluation results in the 
identification of a property or properties that the BOR, SHPO, or 
responsible/cooperating agencies agree nr& eligible for inclusion 
in the NRHP, the BOR shall ensure that they are treated in 
accordance with Stipulation 4 and a Determination of Effect shall 
be prepared and submitted to the SHPO. 

3-8 



4. HISTORIC PROPERTY TREATMENT PLAN(S) (HPTP) 

The BOR will consult with the SHPO, Council, CCWD, and the 
responsible/cooperating agencies to develop mutually accepteible 
HPTP or HPTPs for all NRHP eligible properties in the Project's 
APE. Separate HPTPs may be prepaired for individual components of 
the Project if agreed in advance by the BOR, SHPO, COE, SWRCB, 
and CCWD. Each HPTP will be siibmitted for review according to 
the procedures defined in Stipulation 6. Following its 
acceptance by the reviewing paxties, or completion of the dispute 
resolution procedures in Stipulation 12, the BOR will ensure that 
the HPTP(s) is implemented. 

Each HPTP will take into accoxint the principles, standards, and 
guidance in Archaeolocrv and Historic Preservation; Secretary of 
Interior's Standards and Guidelines (48 FR 44716-44742) , the 
Council's publication Treatment of Archaeological Properties 
(1980), and guidance offered by SHPO. Each HPTP will address, at 
a minimum, the following issues: 

A. The actions that will be taken to protect and conserve 
historic properties. These protective measures may include, 
but should not necessarily be limited to monitoring; 
capping; fencing; land use policy and planning techniques 
such as zoning restrictions, conservation easements, 
protective covenants, general plan revisions, and transfer 
of development rights; and other appropriate measures. 

B. The need for data recovery at sites subject to adverse 
affects. Where data recovery is required at a NRHP eligible 
or listed archaeological site or sites, the HPTP shall refer 
to the research design in the Evaluation, Request for 
Determination of Eligibility and Effect for the Los Vagueros 
Project. Alameda and Contra Costa Counties. California to 
guide that work. The HPTP shall specify the types and 
ajnounts of amalysis that will be conducted, how reports will 
be prepared and distributed, where recovered materials will 
be curated, how interested parties will be invited to 
participate, what efforts will be teiken to interpret the 
results of the investigation (s) to the public, and a 
schedule for accomplishing the study or studies. 

C. Any eligible property, properties, or portions of those 
properties that will be destroyed or altered, without data 
recovery or other treatment; 

D. A schedule for implementation of all treatment measures 
defined in the HPTP. 



5. PROTECTION OF SITES PRIOR TO TREATMENT 

The BOR shall ensure that historic properties scheduled for 
treatment in accordance with Stipulations 2-4 are protected 



3-9 



against damage until applicable treatment measvires are 
implemented. 



6. REPORT FORMAT AND REVIEW 

The BOR shall ensure that all documents prepaired to satisfy the 
terms of this agreement aire responsive to contemporary 
professional standards, the Secretary of Interior's format 
Standards for Final Reports of Data Reco very Programs (42 FR 
5377-79) , and the OHP's Archaeological Resource Management 
Reports f ARMR) ; Recommended Contents and Format (1989) . 
Archaeological sites shall be referred to by their permement 
trinomial designation in all reports. Precise historic property 
locational information shall not be placed in documents for 
public distribution if the release of those data may adversely 
affect the properties. 

A. Unless otherwise agreed to by the BOR, COE, SWRCB, CCWD, 
Council, and SHPO, each document prepared to satisfy the 
stipulations of this agreement, will be submitted by the BOR 
to the responsible/cooperating agencies, Council, and SHPO 
for a 30 day review period commencing on the day of receipt 
by the reviewing party. If the reviewing parties have no 
objection to the findings of the document, or they fail to 
comment in the allotted time, the BOR may assume acceptance 
of the document and implement the subsequent actions 
required for compliance with this agreement, or if no 
further actions are required, the BOR may authorize 
construction of the Project or Project component covered by 
that document. 

B. If objections are raised in the review period, the BOR 
shall consult with the objecting party to alleviate these 
concerns. If objections cannot be resolved to the 
satisfaction of all reviewing peirties, the BOR shall consult 
the Council pursuant to Stipulation 12. The BOR will then 
ensure that the revised document is implemented in a manner 
that takes into account the Council's comments. 

C. Copies of each accepted final report will be submitted 
by the BOR to the Council, SHPO, CCWD, COE, SWRCB, and the 
appropriate Information Center of the California 
Archaeological Inventory. 



7. PARTICIPATION OF INTERESTED PARTIES 

The BOR shall provide the other paurties to this agreement a plan 
defining how interested members of the public will be given 
opportunities to comment on implementation of this agreement. 
The plan will include provisions for involving the Most Likely 
Descendants of Native American groups associated with the 
Project, as identified through consultation with the California 



3-10 



Native American Heritage Commission. To every reasonable and 
feasible extent, the views of the Descendants will be considered 
and integrated into planning and conducting any work involving 
the disturbance or scientific excavation of historic properties 
associated with Native Americans. 



8. CURATION OF RECOVERED DATA 

The BOR shall assist CCWD in assuring that all materials and 
records resulting from the implementation of this agreement are 
curated or otherwise treated in accordamce with the Secretary of 
Interior's Standards and Guidelines, 36 CFR Part 79. A 
curatorial agreement or other provisions for the disposition of 
recovered data shall be reached between CCWD, a specific 
curatorial facility, and other interested parties prior to the 
implementation of any subsurface archaeological studies that may 
be required under the terms of this agreement. 



9. PROFESSIONAL REQUIREMENTS 

All studies conducted under the terms of this agreement will be 
carried out or directly supervised by appropriately trained 
persons who meet the Secretary of Interior's Professional 
Qualifications Standards for the particular field of study 
required in that investigation. The BOR and COE will ensure they 
retain staff meeting the aforementioned standards for the 
purposes of monitoring and implementing the tenas of this 
agreement - 



10, ANNUAL REPORT 

A brief annual report will be prepared by the BOR emd presented 
to the cooperating agencies and the SHPO at the annual meeting 
described below. The Council will be provided a copy of the 
annual report and may attend the annual meeting. 

11. REVIEW OF IMPLEMENTATION AND AMENDMENT OF AGREEMENT 

All paorties to this agreement shall confer euinually on the 
anniversary of its signing unless it is mutually agreed that no 
meeting is necesseury. This emnual meeting will be held for the 
purpose of reviewing implementation of the terms of this 
agreement and to determine whether revisions of the agreement are 
needed. If revisions are needed, the parties to this agreement 
shall consult in accordance with 36 CFR 800.13 to maJce such 
revisions. 

Any peorty to this agreement may also request that it be amended 
by notifying the other parties, whereupon all of the other 
parties will consult in accordance with 36 CFR 800.13 to consider 
such revisions. This request may be initiated any time during 



3-11 



t±ie implementation of this agreement. 

12. DISPUTES 

Should any of the parties to this agreement object within 30 days 
to any documents provided for review pursuant to its terms, the 
BOR shall consult with the objecting party (ies) to resolve their 
concern. If the BOR determines that the objection ceinnot be 
resolved, it shall submit documentation relevant to the dispute 
to the Council with a request for comments pursuamt to this 
stipulation. Any Council comment provided within 30 days of such 
a request will be taken into account by the BOR in accordance 
with 36 CFR 800.6(c)(2) with reference only to the subject of the 
dispute. The BOR responsibility to carry out actions unrelated 
to the dispute will remain unchanged. 

13. FAILURE TO CARRY OUT THE TERMS OF THIS AGREEMENT 

If the BOR fails to carry out the terms of this agreement, it 
must comply with 36 CFR 800.4 through 800.6 for the Project or 
any aspect of the Project that could affect historic properties 
before taking or sanctioning any action. 

14 . TERMINATION 

Any party to this agreement may terminate it by providing thirty 
(3 0) days written notice to the other parties, provided that the 
parties will consult during the period prior to termination to 
seek agreement on amendments or other actions that would avoid 
termination. In the event of termination, the BOR shall comply 
with 36 CFR 800.4 through 800.6 with regard to individual 
undertakings covered or any aspect of the Project covered by this 
Programmatic Agreement. 

CONCLUSION 

Execution and implementation of this agreement evidences that the 
BOR and the COE have afforded the Council a reasonable 
opportunity to comment on the management of historic properties 
affected by the Los Vaqueros Project and that the BOR and COE 
have tadcen into account the effects of the Project on such 
properties in compliance with Section 106 of National Historic 
Preservation Act and its implementing regulations (36 CFR 800) . 

Except as expressly set forth herein, COE, SHPO, BOR, SWRCB, 
Council, and CCWD shall not be required to perform amy act or 
bear any responsibility pursuant to this agreement; nothing in 
this agreement shall be construed to enable a party to avoid its 
obligations under the National Historic Preservation Act or its 
implementing regulations. 

3-12 



ADVISORY COUNCK. ON HISTORIC ERESERVATION 

by: ^-^^^M). A^J^ date: ^A/^ 

TITLE: Elxecutive Director 

BUREAU OF RECLAMATION 

BY: <^U^ ^^- - ^ >vr/ ^ DATE:^^^^^^ 

TITLlTi Regional Director 



ARMY CORPS OF ENGINEERS, SACRAMENTO DISTRICT 

: rAOu^^^ ^- ^y^<-P^ DATE: 4 Dec 92 



BY 

TITLE: District Engineer 



CALIFORNIA HISTORIC PRESERVATION OFFICER 
BY: 



Jh-JL.^. P>^. ^^ date: /^- 5'/- f 2 




'^g:^^^^^ DATE:/ 



7 

ueros Proje 





STATE WATER RESOURCES CONTROL BOARD 

BY: 

TITLE: Executive Director 



Jc^^/d^^^^ DATE: /g/Zo /f i 



3-13 



3-14 



CULTURAL RESOURCES BACKGROUND IISfFORMATION 



Historic Context 



The following prehistoric, ethnographic, and historical information is supplemental 
to the draft environmental impact report/environmental impact statement (EIR/EIS) and 
provides historic context statement required by the U.S. Secretary of the Interior's guidelines 
to evaluate cultural resources. 



Regional Prehistory 



Because of its juxtaposition between the Bay Area and the Central Valley/ 
Sacramento-San Joaquin Delta, discussions of prehistoric research for the Los Vaqueros 
locality must include information from both regions. Because both areas have been the 
focus of considerable archeological investigation and extensive information is available for 
both, the following outlines only those developments that figure prominently in research 
issues discussed below. 

Early archeological investigations in central California focused on establishing 
chronological sequences using temporally sensitive artifacts found in burial association. In 
1939, three basic periods were identified: the Early Period (2500-1500 B.C.), the Middle 
Period (1500 B.C.-500 A.D.), and the Late Period (500-1800 A.D.) (Lillard and Purves 1936, 
Lillard et al. 1939, Moratto 1984). 

In the late 1940s, Beardsley focused on the question of the applicability of the central 
California sequence to the Bay Area. His refinement of the system resulted in the Early, 
Middle, and Late periods being renamed "horizons", which were then subdivided using terms 
such as "zone", "province", "facies", and "component" based on the intersite and intrasite 
similarities or dissimilarities of the archeological manifestations (Beardsley 1954). The 
result of this work was the development of the Central California Taxonomic System 
(CCTS). 

Although Beardsley's approach built additional flexibility into the system, his ad hoc 
expansion of the program into other areas was seen as problematic, especially in light of 
data suggesting that the Early, Middle, and Late Horizons did not occur contemporaneously 
in central California. Gerow (1968) substantiated this by presenting evidence that "Early" 
and "Middle" expressions had existed simultaneously for a substantial amount of time in the 



3-15 



Bay Area. As a result of this observation, the CCTS was reduced to a general, temporary 
framework. 

Ragir (1972) dealt with the drawbacks of the CCTS in her reevaluation of the Early 
Horizon by renaming the time-oriented Early, Middle, and Late Horizons Windmiller, 
Co.sumnes, and Hotchkiss, respectively, after the localities where the distinct cultural mani- 
festations were best represented. In doing so, she gave more significance to the location of 
the site and the cultural materials observed than to the period they (presumably) 
represented. 

Along the same lines, Bennyhoff divided central California into local districts (i.e., 
Cosumnes, Colusa, and Diablo), which put further emphasis on geographic location rather 
than period (Elssaser 1978). Fredrickson, in collaboration with Bennyhoff, continued this 
trend by replacing horizon with the term "pattern", described as "an adaptive mode extending 
across one or more regions, characterized by particular technological skills and devices, and 
particular economic modes" (Fredrickson 1973). 

Fredrickson's synthesis of culture histories from the Delta, Bay Area, and north Coast 
Ranges, based largely on his observations of adaptive behavior, was an outgrowth of this 
concept (Fredrickson 1973, 1974a). While some researchers have applauded Fredrickson's 
attempt to integrate cultural sequences in California, others (Gerow 1974, King 1974) have 
questioned Fredrickson's interpretations of the data used to support his regional chronology. 
King (1974) has argued that Fredrickson's use of evolutionary terms, such as "Faleo-Indian 
Period"; "Lower, Middle, and Upper Archaic Periods"; and "Upper and Lower Emergent 
Periods", to create a temporally integrative scheme makes the distinction between simple 
temporal sequences based on key cultural traits and explication of the processes underlying 
socio-cultural change unclear. Regionwide application of such a heuristic device awaits 
further research. 

When viewed as a hypothesis, Fredrickson's model for the Los Vaqueros Project 
offers many avenues through which to address important research issues in central 
California. The Los Vaqueros Project area, because of its intermediate location between 
regions with established cultural sequences, may provide data that address the applicability 
of a regional chronology. 



Previous Archeological Investigations in the Region 

An archival review of the files of the Northwest Information Center (NWIC) at 
Sonoma State University (SSU) was performed for 23 U.S. Geological Survey quadrangles 
in the project vicinity. Before the current study, the Los Vaqueros area was subjected to 
extensive archeological reconnaissance; however, only two sites, CA-CCo-310 and -417, have 
been excavated wathin the project area and the results of both studies have not been 
published. Virtually no archeological excavation has been performed in the project vicinity, 
and the work that has been conducted has gone unreported. 



3-16 



In the region, however, many archeological sites have been excavated. Excavation 
projects were dispersed and primarily of small scale. Reports were located for excavations 
at 17 archeological sites within this area; several other sites (CA-CCo-31, -138, -312, and 
-313) are known to have been excavated, but the reports were not available. Concentrated 
investigations of watersheds or other geographic units have not been performed. 

Fredrickson's work at CA-CCo-30, -308 and -309 (Fredrickson 1965, 1966), aug- 
mented by work by Moss and Mead at CA-CCo-311 (1967) and Pastron at CA-CCo-30 
(1979) represents the most concentrated subsurface investigation in the project region. CA- 
CCo-30, -308, and -309 all lie within the San Ramon Creek watershed, in the Alamo vicinity. 
In 1965, Fredrickson interpreted the sites as representative of five temporal components 
with reference to the CCTS (Heizer 1949), which was the predominant chronological and 
topological scheme at that time. In this interpretation, the sites represented a continuum 
from early Middle Horizon in the lower stratum of CA-CCo-308 (radiocarbon dated to 4,450 
± 400 years B.P.) to Phase II Late Horizon at CA-CCo-309 (a single-component site 
radiocarbon dated 285 ± 95 years B.P.). Chronologically, CA-CCo-30, a two-component site, 
was placed between CA-CCo-308 and -309, with a Middle Horizon component and a Phase I 
Late Horizon component. Pastron's (1979) excavation at CA-CCo-30 confirmed these two 
components. CA-CCo-308 also contained a mid-Middle Horizon component and a 
component identified as representing a transition phase between the Late-Middle and 
Phase I Late Horizon. This transition phase, estimated to date from A.D. to 300 AD., 
was also identified at CA-CCo-20 and -250 in the Diablo locality and at CA-Ala-290 and - 
309 in the San Francisco Bay region (reports not located). 

A report on the small salvage excavation at CA-CCo-311 (Moss and Mead 1967) was 
inconclusive about chronology and affiliation; however, since the report was published, the 
site has been identified as representing a Meganos intrusion dating to before the Middle 
Horizon/Late Transition Phase (Fredrickson pers. comm.). The site contained both flexed 
and extended burials. Olivella beads of unspecified types; round and rectangular Haliotis 
ornaments; and chert, quartz, and obsidian projectile points, including 13 chert specimens 
described as "ceremonial" were reported in association with burials. CA-CCo-31 in Pleasant 
Hill, which contained extended burials, was assigned by Bennyhoff to the Meganos Aspect 
and was considered contemporaneous with CA-CCo-311 based on bead co-occurrences 
(Fredrickson pers. comm.). 

In the Diablo quadrangle, west of Los Vaqueros, CA-CCo-352 was sampled by 
Fredrickson in 1975. CA-CCo-352 was interpreted as a habitation, activity, and cemetery 
site. Residents are believed to have maintained exchange relationships to import obsidian 
from Napa and shellfish from the bayshore. Fredrickson assigned the site to Phase I of the 
Late Horizon (circa 700 A.D. to 1 100 A.D.), with continuing occupation into Phase II of the 
Late Horizon. 

In Fredrickson's 1965 interpretation, the culture of the Diablo locality during the 
Middle Horizon was dominated by inland adaptations and Central Valley/Delta patterns. 
The Transition Phase, during which there was a significant increase in the use of marine 
mollusks (by a factor of 15-20 times) compared to both preceding and subsequent periods, 
represents an immigration to interior Contra Costa County of a people adapted to a 



3-17 



bayshore economy. The following Phase I Late Horizon shows a group fully adapted to the 
inland environment. Also noted during the Transition Phase was an increase in imported 
obsidian (this trend continued and accelerated in the Phase I Late Horizon as seen at CA- 
CCo-30), a paucity of local lithic materials other than chert, and greater use of imported 
foods. Fredrickson interpreted these changes as representing population movement, rather 
than diffusion. 

The three sites represent intermittent occupation over 4,000 years. The earliest 
group shared traits of the Early and Middle Horizon. A tentative mid-Middle Horizon 
component was also delineated. Cultural affiliation during the Middle Horizon is believed 
to be with the Sacramento Valley with some influence from the Napa Valley. This may 
have been followed by a time (not manifest at CA-CCo-30, -308, -309) when influences of 
the northern San Joaquin Valley were manifest in the Diablo locality. Beginning with the 
Transition Phase, cultural influences of the Bay region are interpreted to represent an influx 
of a bayshore-oriented population. Phases I and II of the Late Horizon artifact assemblages 
in interior Contra Costa County give the impression of affiliations with the Late Horizon 
in the lower Sacramento Valley, along with certain characteristic Delta elements. However, 
interior Contra Costa County groups may not have participated in the ceremonial life of 
populations of the Sacramento Valley or may have participated in such ceremonies in 
attenuated form. 

Fredrickson had refined his interpretation of CA-CCo-308 chronology by 1977, and 
had assessed the deepest component of the site as representing the Berkeley Pattern, which 
was seen as contemporaneous with the Windmiller Pattern of the Sacramento Valley 
(Fredrickson 1977a). He also noted that the lowest component of CA-CCo-308 had cultural 
material under as much as 22 feet of sterile alluvium. Radiocarbon dates of 4,450 ± 
400 B.P., 3,125 ± 230 B.P., and 2,870 ± 335 B.P. were reported for the lowest component 
of CA-CCo-308. A date of 3,000 ± 200 B.P. may be most accurate (Banks et al. 1984). 
Later radiocarbon assessment of samples from the middle component of CA-CCo-308 
yielded additional dates of 1,250 ± 230 B.P. and 2,860 ± 120 B.P., while the uppermost 
component yielded dates of 470 ± 120, 865 ± 50, 940 ± 50, 980 ± 50, and 1185 ± 125 B.P. 
Additional a.ssessments for CA-CCo-30 (upper component) ranged from 265 to 585 ± 
50 B.P. CA-CCo-309 yielded a date of 285 ± 50 B.P. (Fredrickson 1980.) 

Northwestward, in the Walnut Creek area. Banks and colleagues excavated at CA- 
CCo-431 in 1979 (Banks et al. 1984). The site, a buried deposit, appeared to be a sparse 
cultural deposit, possibly at the margin of a more intensively occupied site. Obsidian 
hydration suggested occupation dating to 1,200-2,300 years ago. Three buried surfaces were 
noted; the middle of these was radiocarbon dated as younger than 2,870 ± 120 B.P. The 
cultural affiliation of the site would be the Alamo Phase of the early Berkeley Pattern of 
the Concord Phase of the Windmiller/Berkeley Transition. Trade interactions with Napa 
Glass Mountain area are indicated; whether other sources were used is unknown. Trade 
for chert from a Monterey source is also suggested. 

CA-CCo-236, in Lafayette, was excavated by Baker in 1987. Virtually all time- 
sensitive artifacts from this site, including clam shell and Olivella lipped beads and small 
(Type 1) projectile points, indicate that this site was occupied principally during the latter 



3-18 



part of the Augustine Pattern (Phase II of the Late Horizon), dating from about 1500 A.D. 
to the late 1700s. Heavy use of imported obsidian as raw material, near-complete exclusion 
of chert, and the predominance of clam shells over mussel shells also indicate late use of 
the site. Mortars, pestles, and small arrow points suggestive of bow and arrow use were also 
recovered. Raptor remains could suggest participation in the Kuksu Cult. Evidence of 
extensive trade networks is noted. Banks et al. (1984) present chronological correlations for 
the Diablo District based on the excavations summarized here and elsewhere. 

Somewhat closer to the project area is CA-Ala-413, the Santa Rita Village site, near 
Pleasanton. Sixty-four burials excavated from the site in 1978 were analyzed by Wiberg 
(1984a) as manifestations of a Meganos intrusion. Wiberg did not describe artifacts in detail 
or prepare an artifact typology. The Meganos Aspect, first identified in the northern San 
Joaquin Valley, was described by Bennyhoff (1968) as a merging of Windmiller Pattern and 
Berkeley Pattern elements. A brief expansion of this culture into the Diablo and Alameda 
Districts between the end of the Middle Horizon and the Middle Horizon/Late Augustine 
Horizon transition is suggested by Bennyhoff (Wiberg 1984a). This would correlate with the 
cultural component described for CA-CCo-31 and -311, above. Wiberg writes that two 
alternative dating schemes for the central California archeological sequence date this 
Meganos intrusion at 300 B.C.-lOO A.D., or 500-700 A.D. (Fredrickson 1980). Wiberg 
argues that the Meganos culture was more widespread and longer lasting in some localities 
than previously thought. 

Wiberg distinguished two components at CA-Ala-413. The lower component, radio- 
carbon dated between 400 B.C. and 200 A.D., is characterized by flexed burials with few 
artifacts. Some extended burials occur at the same level as the extended burials or below 
the flexed burials. Wiberg identifies the upper component of the site as a possible Meganos 
intrusion. Radiocarbon dates indicate that the upper component pattern commenced after 
100 A.D. and lasted until 500 A.D. or later. It is defined by exclusively extended burials, 
northerly burial orientation, and abundant grave associations, including thousands of shell 
beads and other shell artifacts, quartz crystals, charmstones, and other nonutilitarian grave 
goods. 

Bennyhoff defined the Meganos Aspect on the basis of mixed flexed and extended 
burials, the latter predominating and interpreted as a Windmiller trait, along with a low 
yield of associated artifacts, a Berkeley Pattern characteristic. Other traits of Bennyhoff s 
Meganos Aspect are an underdeveloped ceremonial system and a relatively undeveloped 
exchange network. In contrast, at CA-Ala-13, the extended upper component burials had 
rich, frequently ceremonial associations, more like classic Windmiller sites. Exchange net- 
works and ceremonial systems appear well developed. Wiberg suggests that the Meganos 
Aspect, as seen in the upper component at CA-Ala-413, represents a survival of the 
Windmiller culture. He speculates that the Windmiller traits surviving from the lower 
Sacramento Valley could be maintained at CA-Ala-413 because of the residents' polifical 
position, gained through local exchange networks. 

Clearly, much more extensive investigation will be required to clearly define 
chronology and cultural patterns in this area. The cultural affiliations defined by Wiberg 
must await confirmation by analysis of the full CA-Ala-413 assemblage. Little has been 



3-19 



reported regarding the artifacts themselves, although Wiberg's illustrations include 
rectangular and round Haliotis ornaments and very large (12- to 17-cm long) obsidian and 
chert blades. 

Ca-CCo-222, located northwest of the project area in Clayton Valley, was excavated 
by Holman and Associates in 1982. Holman suggested the possibility of a Berkeley Pattern 
component for the lower part of the site, with an upper more extensive and better repre- 
sented Augustine Pattern component. These San Francisco Bay region patterns roughly 
equate with Early and Late Horizons of the Sacramento Valley or with Fredrickson's 
(1974a) Middle Archaic and Emergent Periods. Supportive of the Augustine Pattern are 
a clam shell disk bead, obsidian projectile point fragments of late types, a sandstone 
discoidal similar to late Alameda District and Diablo District specimens, shaped mortar 
fragments, and shaped pestles. The primarily Napa Glass Mountain obsidian sources tend 
to conform to the patterns established at other late interior sites. Shell is relatively rare; 
only two shell artifacts were recovered. There is no direct evidence the Meganos Aspect 
in the portion of the site excavated. However, a Berkeley Pattern Middle Horizon affiliation 
for the lowest level of the site is suggested by a radiocarbon date of 2,820 ± 120 B.P., and 
a single basalt point fragment and a expanding stem point made of chert. This sample came 
from a flexed burial that had an associated large leaf-shaped obsidian biface from a Napa 
Glass Mountain source. The upper component yielded a radiocarbon date of 1,600 
± 200 B.P., too early to represent Phase II of the Augustine Pattern evident in other areas 
of the site. Horizontal stratification may occur at the site, and although the cultural 
chronology of this site is not clear, at least some portion of the site probably represents the 
Phase II Late Horizon (Augustine Pattern). 

Another site or site complex in the Clayton vicinity, CA-Ala-312/313, was excavated 
by California State University, Hayward in 1969 (no report is available). At least 1,000 
artifacts and 15 burials were recovered. Artifacts indicate that "occupation began during the 
initial stages of Phase I Late Horizon (c. 700 A.D. to 1000 A.D.) and terminated after the 
introduction of desert side-notched points, Ca. 1450 A.D." (Baker 1991). No other 
information is available at NWIC regarding this assemblage. 

Near Antioch, two sites, CA-CCo-385 and -386, were excavated by King in 1979. 
King postulates settlement at CA-CCo-386 before 1000 A.D., based on the absence of late- 
period artifacts and the presence of many fragments and obsidian flakes "retouched from 
large knives" (King 1979). Features included hearths and pits. Few additional data were 
presented. CA-CCo-386 was viewed as a habitation site; CA-CCo-385 was viewed as an 
activity area. 

Eastward into the Delta, two burials were salvaged in 1977 from CA-CCo-368 on the 
Hotchkiss tract. One was extended on its side, the other flexed ventrally. A bowl mortar 
was associated with one burial. The site, a midden deposit on a Delta sandhill, was assumed 
to be of the ethnographic period, based on the presence of dark midden rather than the 
typical "burial island" sand mound of earlier types in the Delta (Miller et al. 1977). 

South of the project vicinity, near Altamont, McGeein and McGeein excavated at 
CA-Ala-28 in 1957. Nine house pits in a dark gray midden were recorded. Only 53 artifacts 



3-20 



were recovered from over 50 cubic yards of excavated material. The assemblage included 
hopper mortars; bone awls; bird bone tubes; scapula saws; Haliotis ornament fragments; 
Olivella beads; large obsidian and chert projectile points; and chert, chalcedony, and quartz 
blades. Two burials were uncovered: one the remains of a tightly flexed infant, the other 
fragments of an adult. On the basis of the faunal assemblage, which included a variety of 
fish and animal bone, the site was postulated to have been occupied during late fall, winter, 
and early spring and was believed to date to the precontact Late Horizon. 

West of this site, within the Livermore quadrangle, Parkman excavated at CA-Ala- 
394 in 1974. A letter regarding field notes from the site reports that the site, deeply buried 
by alluvium, "was low yield in nature" (Parkman 1977). Five extended and one flexed burial 
were reportedly excavated from the site vicinity by local residents. Numerous scrapers and 
other chert and obsidian tools, a bone awl, and a bird bone tube were recovered. Parkman 
postulated that the site was an early Middle Horizon or late Early Horizon deposit. 
Fredrickson (1977b) examined the notes and came to a similar conclusion, although he 
noted that more current terminology would equate Early Horizon with the Windmiller 
Pattern, Middle Horizon with the Berkeley Pattern, and Late Horizon with the Augustine 
Pattern and that he would assess the site as belonging to the Berkeley Pattern. 

South of the Pleasanton site, Leventhal et al. excavated at CA-Ala-428/H in the 
Sunol Regional Wilderness. Leventhal assigns the site to the Middle Period in dating 
scheme Bl of Bennyhoff and Hughes (1987) and believes that the site predates 900 A.D. 
This chronological assignment is based on large projectile points classified as dart points 
(rather than arrow points). Mortars and pestles from the site are unshaped, and two manos 
(but no metates) were noted. One clam shell disc bead, a Late Horizon Phase I or 
Augustine time marker, was collected from the surface. Six of seven obsidian pieces 
collected were identified to be from Napa; a seventh specimen may have come from east 
of the Sierra. Radiocarbon dates did not confirm this assignment: four dates, all on 
samples that were somewhat suspect, included modem, 1507 A.D., 1409 A,D., and 982 A.D., 
obsidian hydration-derived dates that were not consistent with radiocarbon dates. 

Data from these sites are presented to contribute to hypothesis formulation for the 
Los Vaqueros area. Correlation of these regional chronological signatures with the Los 
Vaqueros area is one of the main research topics guiding future archeological work. 



Ethnographic Setting 



The following summarizes the history of Native American involvement in the Los 
Vaqueros region and addresses contemporary Native American concerns and interests 
concerning the reservoir project. The methods used to gather data for this section include 
oral histories, ethnohistory, cultural geography, folklore studies, ethnoastronomy, 
comparative ethnography, mission record research, linguistics, and archeology. 

Preliminary interviews were conducted with the Native Americans most likely 
descendants (MLDs) for the Los Vaqueros Project regarding their knowledge of the region. 



3-21 



Most MLDs knew a great deal about their family histories in the Livermore-Pleasanton area 
during the 20th century, and the older MLDs also knew about late 19th-century family 
history. One MLD now in his 70s grew up 1 mile north of the Los Vaqueros Project site. 
He was knowledgeable about the use of plants and rockshelters in the area. Several MLDs 
told creation stories relating to Mount Diablo and the area to the east. All 
Ohione/Costanoan and lone Miwok MLDs could trace their family histories in the 
Livermore-Pleasanton area back to the 19th century. 

The research conducted for this section indicates that a wealth of information and 
research potential exists to develop a detailed history of Native American presence in 
eastern Contra Costa County. For instance, during the early ethnohistoric period 
(approximately 1780), the area around Kellogg Creek was the contact zone for four linguistic 
groups: Bay Miwok, Ohlone, Yokut, and Plains Miwok. This juxtaposition of groups permits 
research of intergroup relationships, such as trading, intermarriage, and intergroup conflict. 
Information from this area would be applicable to regional studies of central California; to 
the dynamics of intergroup relationships throughout the state; and to the theories of 
intertribal political, economic, and social relations. 

The following is a synthesis of information regarding Native American use of the Los 
Vaqueros area during prehistoric and historic times. 



Native American Prehistory 

Los Vaqueros was probably not the permanent home of any tribe when the first 
Euroamericans entered eastern Contra Costa County (circa 1780), because no permanent 
village sites have been found during archeological surveys of the upper Kellogg Creek area 
(Sonoma State Academic Foundation 1992). The Kellogg Creek area was bordered by four 
Native American linguistic groups: the Bay Miwok to the north, the Ohlone to the 
southwest, the Yokuts to the southeast, and the Plains Miwok to the east (Callaghan 1982). 

The Native Americans who used the upper Kellogg Creek area may have occupied 
permanent villages in Round Valley or along Marsh Creek to the northwest, which have 
been attributed to the Volvon tribelet of the Bay Miwok (Fredrickson pers. comm.; Milliken 
1982). Linguistic, ethnohistoric, and mission record evidence suggest that either the Volvon 
tribelet or the Saoam (Ohlone) tribelet used the Los Vaqueros area (Callaghan 1982; 
Milliken 1982). During the period immediately preceding Euroamerican settlement, the 
Volvon and Saoam tribelets had populations of at least 100 people each, according to the 
baptismal records of Mission San Jose and Mission Dolores (Milliken 1982). 

Archeological sites in the project area are primarily temporary campsites, which 
suggests that the area was probably used for specific, temporary purposes, such as plant 
gathering and hunting. As elsewhere in California, it is presumed that people using the 
project area followed a seasonal round, gathering food in large quantities and using 
processing techniques to dry the food for long-term storage (Bramlette at al. 1991). 



3-22 



During fall and spring, grasses were burnt off while they were still damp and not a 
fire hazard. The ash from these controlled bums fertilized the soil, creating hillsides of seed 
plants and meadows to attract small animals, and cleared the growth under food trees to 
facilitate the fall harvests (Bramlette et al. 1991, Lewis 1973). 

Establishment of camps in late summer and early fall served both economic and 
social purposes. Groups of women harvested and processed seeds and acorns, while men 
herded and harvested migratory animals. During this time, young men and women from 
neighboring villages could meet and court. 

To protect against the summer sun, temporary ramadas were probably constructed 
near springs. The rockshelters and oak and buckeye trees also offered shade. Little or no 
clothing was worn (Callaghan 1982, Milliken 1982). 

In the rainy winters, men hunted abundant migrating herds of large animals. The 
winter economic group was smaller and the time spent away from home was shorter than 
in summer. In the winter villages, men and women repaired their utensils and equipment. 
The main economic technology was basketry, with constructed items including gathering 
baskets, processing and cooking utensils, clothing, housing, and nets. 

The tribes of eastern Contra Costa County were in contact with each other through 
trade and intermarriage, although most individuals did not travel far from home in a lifetime 
(Bramlette et al. 1991). The dynamic resource diversity between the grassy inland hills and 
the Delta marshlands resulted in a widespread trade network. Large trading villages were 
located along the Delta at Antioch, Concord, and Clayton (Kroeber 1962b). 

As a result of intertribal marriage, many families spoke more than one language. 
This interrelationship is also evident in the mission records of marriage, baptism, and death 
(Callaghan 1982, Milliken 1982, Bramlette et al. 1991). 

In a world without writing, religion functioned as the primary institution to maintain 
and transmit ideas about world order and cultural structure. Native California was made up 
of small tribes without chiefs or the centralized political apparatus of the state. Politics and 
religion were inextricably intertwined. A leader's role was both political and religious in 
scope and application (Davis 1988). 

While political boundaries divided the tribes, religion united the people. Religion was 
the major organizing principle for the calendar, the economy, cycles of social life, trading 
networks, political leadership, intertribal relations, and postcontact population movements. 
Astronomical observations, medicine, and geography were closely related to religion, and 
art was a means to express these ideas (Davis 1988). 

Exotic materials were traded between tribes and used in ceremonies. Religious 
leaders from several tribes met at intertribal ceremonies to celebrate and renew the world 
order. Religious mythology transmitted cultural values and the principles and processes of 
world order from generation to generation. The religious calendar organized the year by 
marking and predicting harvest seasons and matching them with ceremonies and astro- 

3-23 



nomical events. Religion was the primary adaptive mechanism for cultural persistence 
and yet acted as a powerful agent for Native Americans adjusting to cultural change (Davis 
1988). 

It appears that the Los Vaqueros area was used for religious activity, as indicated by 
temporary camps located near and in the Vasco Caves, and by early references to "Indian 
ceremonial sites near Mt. Diablo" (Contra Costa Water District 1992). Vasco Caves at Los 
Vaqueros and Walker Caves at Brushy Peak have been painted with images of possibly 
religious nature, and both caves are located along the sight line of the winter solstice from 
Mount Diablo (Bramlette et al. 1991, Contra Costa Water District 1992). Similar painted 
caves are also located at Buena Vista Peak near lone, along the summer solstice line from 
Mount Diablo. The lone area was the resettlement location of some eastern Contra Costa 
County Native Americans after the missions were secularized. Round Valley, the possible 
home of the people who used Los Vaqueros, is related in mythology to Mount Diablo, 
Vasco Caves, Walker Caves, and Brushy Peak, and is also located along the winter solstice 
sight line from Mount Diablo (Contra Costa Water District 1992). 

The Diablo religious district was shared by many distinct political tribes whose 
religious leaders likely gathered periodically to renew the world system. Only the religious 
leaders would have known the boundaries of the Diablo political-religious region (Contra 
Costa Water District 1992). 

The Historic Period 

1770-1803: Explorers, Disease, Military Force, and Missionization of Native 
Americans, and Native American Resistance. The first non-native explorers to come 
through Contra Costa County were from the Spanish missions: Pages in 1772 and Anza in 
1776. Sal led an expedition over Altamont Pass in 1795. For over a month in 1805, 
Arguello scoured Livermore and Diablo Valleys to bring the remaining Native Americans 
into the missions (Milliken 1982, Bramlette et al. 1991). Moraga took an exploring party 
over Altamont Pass in 1808 (Beck and Haase 1974). 

The missions sent out military teams into the county to recruit and coerce Native 
Americans. With a series of aggressive sweeps, all 100 Saoam people were brought into 
Mission San Jose between 1803 and 1805, and all 100 Volvon were brought into Mission San 
Jose and Mission Dolores in 1805 and 1806 (Milliken 1982, Bramlette et al. 1991). 

Tlie world was in upheaval for Native Americans during this period. At least one 
epidemic occurred, carried by runaway Saclan and Huchiun people from Mission Dolores 
in 1795, that likely affected many native people of eastern Contra Costa County even before 
they went to the missions (Milliken 1982). Within 20 years of contact with Euroamericans, 
most of their people were permanently removed from their homes or died in great numbers 
from epidemic diseases. The old ways of protection and resistance did not work against the 
new dangers, and Native Americans were just beginning to develop new strategies of survival 
and cultural persistence. From the beginning, Native Americans were drawn back to their 
homelands and escaped from the missions to find their way back to their tribal territories. 
The Spanish tracked down the runaways, punishing some, killing some, and taking the 



3-24 



survivors back to the mission. In 1806, the powerful Volvon tribe from the Diablo District 
organized a resistance movement against the raids (Milliken 1982). 

1803-1834: The Mission Era. Soon after being brought to Mission San Jose, 
the Saoam and Volvon were exposed to the measles epidemic of 1806 (Milliken 1982). Life 
at the missions was structured toward changing the beliefs and behavior of Native 
Americans. However, the native people continued to practice their religions, in public if 
they could, but more often in private and secretly even in the sure knowledge of punishment 
if the mission padres caught them worshiping in the old way. The Kuksu Cult may have 
appeared in the missions during this period (Callaghan 1982). The aboriginal political 
affiliations among tribes were apparent in the sociology of mission life, with intertribal 
marriage occurring among allied tribal groups (Milliken 1982). 

Although some of the Native Americans at Mission San Jose lived and worked at the 
mission, others were sent to the mission ranches of eastern Contra Costa County, probably 
to Los Vaqueros, as laborers and cowboys. The Saoam or Volvon who survived the 
epidemics may have been chosen to return to their homeland, the land they knew, to work 
on the mission cattle ranches in Livermore Valley and at Los Vaqueros. By 1828, Father 
Duran of Mission San Jose had drawn a map of mission lands on the frontier (including the 
entire Livermore Valley) as a summer cattle ranch from which cattle were moved, probably 
through Los Vaqueros canyon, to spend the winter in the Concord area (Milliken 1982). 

The Mokelumne and Lokelumne (Plains Miwok people who trace their 19th-century 
family histories to eastern Contra Costa County) probably began their involvement in the 
area during the mission period. Between 1817 and 1835, 143 Mokelumne people were 
baptized at Mission San Jose. Fifty-two Lokelumne people were baptized at Mission San 
Jose between 1826 and 1834 (Levy 1978b). 

The largest ethnic group at Mission San Jose consisted of the many tribes of the 
Plains Miwok, including the Mokelumne and Lokelumne, with 2,100 baptisms from 1811 to 
1834 (Levy 1978b). Once taken to the missions, the Plains Miwok organized runaway 
groups to return to the Delta marshlands. By the 1830s, the missions were closing down and 
provided less services to their native populations. With disease killing their families and 
missionization destroying their cultures, many neophyte Native Americans chose the 
dangerous option of escaping from the missions to join the growing resistance movement of 
tribal and runaway Native Americans led by Miwok leaders from the Delta and the Sierra 
Nevada foothills. In time, runaway Native Americans learned the methods of their captors 
and began to retaliate against the missions and frontier settlements (Beck and Haase 1974). 

Expeditions were sent from the missions to capture runaway neophytes and to punish 
Native Americans raiders (Beck and Haase 1974). Sanchez led Spanish attacks against 
Native American villages along the Mokelumne River in 1819 and along the Cosumnes 
River in 1825. 

Instead of becoming involved in resistance activities, many Native Americans stayed 
at the missions, adapting to the requirements there by learning the new roles of laborer and 
cattle herder, and adjusting culturally through religious interpretation and revitalization. 



3-25 



conducting traditional dances and the new Kuksu ceremonies (Milliken 1982). For those 
who remained, the mission period was a time of Native American adaptation to the imposed 
order, an adjustment of the old traditions to new circumstances and, in many ways, the 
persistence of the old moral order within the Native Americans community. Although there 
was a new day-to-day intertribal sociology at the missions, with caste divisions between the 
Native Americans and non-Native Americans, the continuation of the old intertribal 
marriage alliances was an example of what must have been a variety of tribal boundary 
maintenance behaviors within the uncomfortable intertribal intimacy of the mission walls 
(Milliken 1982). 

1834-1849: Ranchos, Vaqueros, and Native American Raiding. The new 

Mexican government in California intended to separate itself from the administration of the 
missions through the Secularization Law of 1834 by passing mission lands into the hands of 
the remaining mission Native Americans, with only unclaimed land to be deeded to Mexican 
ranchers. However, the mission fathers reported that all the Native Americans had died so 
that the vast mission land holdings would be deeded by the Mexican government to 
non-Native Americans. 

The Kellogg Creek area, considered a grazing tract on the eastern frontier of 
desirable mission lands, was included in the deed to the Los Meganos Rancho given as a 
Mexican land grant to Jose Noriega in 1835. He sold it to an American, John Marsh, in 
1837. In 1844, Marsh ceded the southern portion, including the majority of the Kellogg 
Creek watershed, to Francisco Alviso, Antonio Hiquera, and Manuel Miranda as the 
Rancho Canada de Los Vaqueros (Bramlette et al. 1991). 

After the missions were secularized in 1834, many Native Americans returned to their 
homelands, but they lacked the survival skills of their parents. Some, including the Volvon 
and Julpun from Mission San Jose, went to work as laborers and vaqueros for the ranchos 
in their home territory of eastern Contra Costa County at the large cattle ranches at Los 
Vaqueros and Los Meganos (Milliken 1982). 

The Mexican landowners considered the Native American workers an integral part 
of their ranches and allowed them to continue to live at traditional village sites (Milliken 
1982). The Native American workers on the ranches were laborers and cowboys. An 
annual rodeo was held at Los Vaqueros, and skilled Native American vaqueros likely 
participated (Bramlette et al. 1991). 

Marsh lived at Los Meganos from 1837 until his death in 1856. He initially built a 
small adobe house and later, in 1851, a stone mansion, probably with the help of Volvon 
and Julpun people. The Los Meganos Native American laborers also helped to plant a 
vineyard and an orchard, sowed the first wheat fields in Contra Costa County, and raised 
cattle (Bramlette et al. 1991). 

Although stock raising was the main economic pursuit of the Los Meganos and Los 
Vaqueros ranches, Marsh and John Sutter were known to have exchanged Native American 
laborers for agricultural purposes at planting and harvesting times, thereby setting up a new 



3-26 



social network between the Ohlone/Bay Miwok and the Plains Miwok/Maidu (Villa and 
Dutschke 1982). 

Native Americans east of the Delta and foothills did not settle into the laborer's class 
of Mexican society. The Plains Miwok from the Central Valley and Sierra Nevada Foothills 
organized intertribally into a resistance movement, shifting their social structure and 
changing their economic base to survive when their homelands were taken and their old 
lifestyle was no longer possible. The Plains Miwok had spent the last 10 years in the 
missions, dominating other tribes by their numbers. Other tribes had lived in the missions 
for up to 50 years. The Plains Miwok, however, were in the missions only long enough to 
learn some tricks from their captors without being away from their traditional life too long 
to have become submissive to the new order. They changed from peaceful, sedentary, local- 
ized groups into a unified semiwarlike, seminomadic, multitribal resistance movement (Beck 
and Haase 1974, Milliken 1982, Levy 1978). 

In the 1830s, the Native American resistance routinely attacked the missions, ranchos, 
and towns, taking large numbers of horses and cattle and injuring or killing non-Native 
Americans (Milliken 1982). Plains Miwok and Yokut raiders probably crossed the San 
Joaquin River between Byron and Tracy, traveling across Altamont Pass to raid the ranchos 
in Contra Costa and Alameda Counties. The ranches most under attack were probably Los 
Vaqueros and Los Meganos, the westernmost ranches on the frontier of Mexican California 
and the least protected by the Presidio soldiers and therefore the most accessible and 
vulnerable to horse and cattle raiders from the east. 

After control of California passed from Spain to Mexico in 1822, expeditions into the 
interior continued, but with a changed purpose. Instead of seeking inland sites for possible 
missions, soldiers were sent into the interior to recover stolen animals and punish hostile 
Native Americans and to reduce the attacks on towns, missions, and ranchos. In 1829, three 
expeditions were sent against Estanislao, a former mission Native American, leader of 
runaway Native Americans on the Stanislaus River (Beck and Haase 1974). 

The secularization of the missions had once again drastically affected the lives of the 
Native Americans. Some tried to return to their old ways of life by returning to their 
traditional territory and found that survival was difficult without the social, material, and 
economic strategies they once had. Others continued to adapt to the changes by working 
on the Mexican ranchos as laborers and vaqueros, building adobe houses for the landowners, 
sowing and harvesting agricultural crops, practicing animal husbandry, and participating in 
rodeos. This allowed them to maintain a remnant of the traditional social structure because 
they were allowed to establish their own rancherias on the ranchos. However, their lives 
were as dependent slaves or serfs, and they were coerced into long-distance labor exchanges 
between ranch owners, which in turn led to new social ties between Miwok, Ohlone, and 
Maidu people. 

Other Native Americans continued to live the risky lives of resistance fighters in the 
resistance movement centered in the Delta and Sierra Nevada foothills. While the warriors 
and raiders lived a Native American way of life, it was a new way of life. Their homelands 
had been taken and their old lifestyle was no longer possible, so rather than adapt to the 



3-27 



lifestyle of the invaders, they had shifted their social structure and changed their economic 
base to survive. They changed from peaceful, sedentary, localized groups into a unified 
semiwarlike, seminomadic, multitribal resistance movement, facing the threat of constant 
military retaliation (Beck and Haase 1974). 

1820-1840: American Mountain Men and Immigrant Parties. During the 
1820s to 1840s, American mountain men like Jedediah Smith, Ewing Young, and Joseph 
Walker traveled through the Bay Area and over Altamont Pass to Mokelumne and Loke- 
lumne territory, trapping beaver along the San Joaquin and Sacramento Rivers. Although 
the trappers' policy was to avoid conflict, their presence added to the already volatile 
situation of Euroamerican-Native American conflict (Beck and Haase 1974). 

Following the routes that these explorers had forged, American immigrant parties 
began arriving overland into California. The Bartelson-Bidwell immigrant party traveled 
down the Stanislaus River and stopped at Marsh's ranch in 1841 (Beck and Haase 1974). 
Marsh was the only American landowner in this area of Mexican land grants, and his ranch 
became a major rest stop for the American immigrant parties. 

Although the American explorers and trappers were the first white men Native 
Americans had seen in some areas of the state, this was not the case for the Ohlone and 
Miwok in the Bay Area, Delta, and foothills. It was probably unnecessary for the Native 
Americans to adapt to these foreigners, because they stayed in an area for only a day or two 
and their policy toward Native Americans was nonaggressive. The major contribution of the 
American explorers was in the diaries they kept of their journeys. 

However, the situation between Native Americans and settlers was different. The 
settlers required land and took it forcibly from Native American inhabitants. Their 
homesteads were targets for Native American horse and cattle raids. Although a homestead 
family did not put up much of a fight against the hit-and-run tactics of raiding Native 
Americans, citizen militias retaliated against Native American family settlements with 
genocidal brutality. Local newspapers recorded the elimination of Native American 
populations with self-righteous fervor. 

During this period. Native American populations decreased drastically. Because they 
could not settle on any land, they could not practice their natural harvest and storage 
economy. While tens of thousands of Native Americans survived the missions, only a few 
thousand survived the settlers (Cook 1976). 

1845: The Bear Flag Revolt. In the early days of the Bear Flag Revolt (the 
American overthrow of the Mexican government in California) John Charles Fremont led 
a small force in 1845 from Truckee's Pass to San Francisco, crossing the San Joaquin River 
around Antioch and traveling north of Mount Diablo through Clayton to Oakland (Beck and 
Haase 1974). His American military presence added to the waves of foreigners moving into 
Native American land east of Mount Diablo. 

1849-1860: The Gold Rush. The Mother Lode was located in the hills directly 
west of Mokelumne and Lokelumne territory, near Jackson and San Andreas. The Plains 



3-28 



Miwok, including the Mokelumne and Lokelumne, who had been raiders a decade before, 
went to the lone area during the Gold Rush. Some Native Americans worked in the gold 
mines, especially for large mining operations in the early days. However, when thousands 
of miners invaded the Mother Lode, individual mining claims took over most of the Sierra 
Nevada gold country, and thousands of Native Americans were killed by miners and settlers 
(Levy 1978b). 

Other Miwok and Ohlone stayed in eastern Contra Costa County to work as laborers 
and vaqueros on the ranches and farms in the Los Vaqueros area, Livermore, and 
Pleasanton (Contra Costa Water District 1992). The need for cattle as meat, rather than 
for hide and tallow, increased with the influx of thousands of men during the Gold Rush. 

The principal crossing of the San Joaquin River in the northern San Joaquin Valley 
was probably located at Stockton, where the Gold Rush routes from Oakland and San Jose 
crossed the river. The route had a stopover at Marsh's ranch and passed next to Los 
Vaqueros (Beck and Haase 1974). The area's non-Native American population was larger 
than it had ever been. 

The Gold Rush was the most destructive era for Native Americans. Native 
Americans under the protectorship of non-Native Americans were the only ones to survive 
this era. 

1851: Treaty Commissioners and the U.S. War Department. Because of the 
increasing conflict between the American miners and the indigenous people of California, 
the U.S. War Department sent treaty commissioners to negotiate treaties with California 
Native American leaders, promising them reservation territory and sovereign nation status 
in exchange for ceding their lands to the government. The Treaty of Camp Fremont was 
signed on March 19, 1851, for the Native Americans of the Bay Area. The Treaty of Camp 
Cosumnes was signed on September 18, 1851, for the Native Americans in the Sierra 
Nevada foothills around lone. None of the California treaties were ratified by the U.S. 
Congress. However, after the treaties were signed, the status of Native American people 
and their rights to aboriginal land changed. 

1851: The Land Grant Commission. The Land Commission of 1851 estab- 
lished the ownership and territories of the Mexican land grants (Beck and Haase 1974). 
The Los Vaqueros case continued for decades. Los Vaqueros was gradually subdivided into 
tenant farms, which negatively affected the Native American people living and working in 
the area. The large land grant cattle ranches required cheap Native American labor and 
permitted Native American workers to maintain their social structure by allowing them to 
live in rancherias within the ranch boundaries. When the ranches were subdivided into 
tenant leases, the Native Americans were forced to either leave the ranches or break up 
their rancherias and work individually on the new smaller ranches (Levy 1978b). 

1850-1900: Cattle Ranching, Subdivision of Land, and Religious Revital- 
ization. Transportation and communication were developing in the Los Vaqueros area in 
the late 19th century, with the stagecoach line passing through Byron and Brentwood (near 
Los Vaqueros), and the Tulare Railroad passing only 2 miles from Los Vaqueros ranch by 

3-29 



1873. Some Native Americans were living on or near the ranches, working as laborers and 
vaqueros and possibly in the construction of the railroad (Milliken 1982). 

Although from 1847 to 1900, the U.S. War Department was responsible for handling 
the conflict between the settlers and the Native Americans, to protect the settlers from the 
Native Americans and to protect the Native Americans from attacks by the settlers, the 
army did little to help the native people of the Bay Area and lone. Native Americans died 
at a high rate from disease, such as the Contra Costa epidemic of 1853, and from the attacks 
of miners and settlers (Milliken 1982). The native people in both areas were suffering, and 
their traditional cultures continued to disintegrate. Native Americans of eastern Contra 
Costa County adapted by working in the lower ranks of the laboring class of American 
society. 

During this era, most of the Mokelumne and Lokelumne ended their stay in eastern 
Contra Costa County and moved permanently to lone. They lived partly by traditional 
hunting and gathering and partly by seasonal labor (Levy 1978b). In the late 19th century, 
the plight of the Miwok in the lone area was recognized. Two federal rancherias and one 
private rancheria were set aside for the Native American communities: the Buena Vista 
Rancheria, established in the late 1800s; the Jackson Rancheria, established in 1893; and 
the Moffitt land, established in the late 1800s (Contra Costa Water District 1992). 

The Ghost Dance religion spread through this area during at least two surges of 
religious revitalization: in the 1870s when prophets came from Pleasanton-Livermore, and 
in the 1890s (Villa and Dutschke 1982). Reports also exist that the Kuksu religion, a native 
revitalization religion, was being practiced in the Diablo area (Callaghan 1982). Intertribal 
religious ceremonies and regional gatherings were reportedly also being held at the base of 
Mount Diablo in the late 19th century (Ortiz 1989). Reports of these various religious 
activities are probably related. 

Mission San Jose continued as a viable institution in the Native American 
communities and a central religious institution for converted Catholic Native Americans, 
with an orphanage and other programs for the Native American community (Contra Costa 
Water District 1992). 

1900-1940: Ranching, Farming, and Cultural Disintegration. The Ohlone 

families that lived in eastern Contra Costa County at this time worked as laborers on farms 
and cattle ranches or worked on construction projects of the Balfour-Guthrie Company, 
which owned Los Meganos Ranch. Many of these families stayed in eastern Contra Costa 
County until the 1940s (Contra Costa Water District 1992). 

Most of the Ohlone families stayed in the towns of eastern Contra Costa County, 
Livermore, Pleasanton, Dublin, and Brentwood. Some Native Americans went back to 
Mission San Jose as orphans or to live on mission land (Contra Costa Water District 1992). 



3-30 



During this era, some families moved into non-Native American communities, 
especially Mexican-American families, and began to publicly identify themselves as 
Mexican-Americans. The sense of indigenous heritage (which traditionally had been 
expressed as an identification with a tribal community located in a specific geographical 
area) was being replaced with an increasingly uninformed sense of Native American identity. 
However, a strong sense of extended family remained for many, as noted by family reunions 
and expressed as a high regard for elders and their knowledge (Contra Costa Water District 
1992). 

1940-1975: Little Native American Activity at Los Vaqueros. Most Ohlone 
families moved away from the Livermore-Pleasanton area during this time and used the hills 
and streams occasionally for family gatherings (Contra Costa Water District 1992). Family 
gatherings continued to be an important way of transmitting and expressing Native American 
cultural background, through telling stories of family history. 

1975-1992: Renaissance of Interest in Eastern Contra Costa County. With 
the development of various projects in eastern Contra Costa County over the last 20 years, 
the wind turbines, and various Los Vaqueros projects, lone, Miwok, and Ohlone people have 
begun to talk to older family members about their histories specific to this area. As they 
hear about or see the Vasco Caves, they express a strong emotional and spiritual connection, 
generally and specifically regarding ties to the creation stories and sacred geography around 
Mount Diablo (Contra Costa Water District 1992). 

A statewide California Native American religious revival has been developing 
dramatically in the last decade, and a growing public interest in Native American culture 
and history has also increasingly encouraged Native American descendants to turn their 
attention toward finding out about their ancestral ways. Dutschke, a Miwok MLD, works 
for the State Office of Historic Preservation. 

Since the 1970s, California and U.S. laws have required land developers to notify 
Native Americans when burials or cultural resources will be disturbed by development. In 
the late 1970s, the Native American Heritage Commission was established in California to 
assist developers to locate and contact the MLDs for any area of the state. This has 
generated a great deal of interest among Native Americans in working on projects of culture 
and history and learning more from their elders. The MLDs involved in the Los Vaqueros 
Project have all worked with other public or private land developers on the disposition of 
burials and cultural resources. 

1992: Contemporaiy Native Americans Concerns. California state law 
mandates that Contra Costa Water District contact the individuals on the MLD lists for 
eastern Contra Costa County about the Los Vaqueros Project. However, several Miwok and 
Ohlone Native American organizations exist whose MLD and non-MLD members have a 
history in eastern Contra Costa County. 

The organized Ohlone groups with an interest in the Los Vaqueros Project are the 
Muwekma Tribe and the Ohlone Tribe. The organized Miwok groups with an interest in the 
Los Vaqueros Project are the Jackson Rancheria, the Buena Vista Rancheria, the lone Band 



3-31 



of Miwok Indians, the lone Band of Indians, and the Amador Tribal Council. The Jackson 
Rancheria and the Buena Vista Rancheria are federally recognized. The other Native 
American organizations are not federally recognized, although the Muwekma Tribe and the 
lone Band of Miwok Native Americans are seeking federal recognition. 

The lone Miwok and Ohlone MLDs interviewed are now intensely interested in 
participating in the Los Vaqueros Project (Contra Costa Water District 1992). 



Cultural Context for Historic Archeology 

As discussed below for the theoretical orientation for historical archeology, it is 
necessary to understand the historical context to determine the importance of historic-period 
resources, especially within the framework of a district. The following provides the historical 
context statement and supporting data for the project area. 

Between 1834 and 1846, more than 800 patents of land, constituting more than 12 
million acres, were issued to individuals by the Mexican government in what is now 
California (Lavender 1976). Sixteen of the final 813 grants were in present-day Contra 
Costa County (Beck and Haase 1988). The lands granted by the Mexican government were 
known as ranchos. Under the rancho system, land outside of towns was considered valuable 
only for grazing purposes; thus, any citizen of good character with cattle and funds for fees 
and taxes could get a grant for a grazing tract. Grantees were required to submit a diseno 
(i.e., a description and map) of the area they desired. The rancho boundaries marked on 
the disenos were usually vague and indicated only by major landmarks. 

Francisco Alviso, Antonio Hiquera, and Manuel Miranda (three brothers-in-law) were 
awarded Canada de Los Vaqueros (Valley of the Cowboys) on February 29, 1844. Three 
years before being granted the land, Alviso had already built a large corral and stocked his 
ranch with livestock. The three grantees probably did not reside full time at Los Vaqueros; 
they did, however, take an active role in supervising the Californios and Native Americans 
in their employ. These employees lived in a wooden house on the ranch (Land Case 
#79:7-19). 

Stock raising was the main economic pursuit during the Mexican period. Land was 
not developed for agricultural purposes more intensive than subsistence-level farming. With 
a relatively sparse and scattered population and a poor transportation system, commercial 
agriculture was not economically feasible during this period in most locales. Because 
ranchos were not fenced, cattle and other stock roamed at will and mbced with stock owned 
by neighboring rancheros. At least once a year a rodeo was held and each ranchero herded 
his own stock back to his land. Los Vaqueros rancho reportedly contained a rodeo site 
(DeNier 1928). 

The first building erected on a rancho was usually of either wattle or palizada 
construaion. Palizadas were easily constructed log buildings chinked with mud and tules 



3-32 



that served to prove a claimant's intention to settle. More permanent adobe structures were 
usually constructed after the land claim was confirmed. 

On July 7, 1846, following the declaration of war between the United States and 
Mexico, Commander Sloat claimed California for the United States, causing a minor influx 
of Americans to California. When the first Americans arrived, Mexican livestock grants 
covered most of the best land, curbing settlement. The prior claim of the Mexican grantees, 
however, did not stop the influx of immigrants, and many squatters eventually appeared 
throughout the county following the announcement of the California gold fields in 1848 
(Smith and Elliot 1879). Many Gold Rush immigrants sought land to take up ranching and 
farming. 

Mexican land grants were written that gave the boundaries of one claim as that of 
another; Los Meganos, for example, was described as being bordered by Los Vaqueros to 
the south. As finalized by the U.S. Land Commission, these grants often contained much 
less land than that originally described; the land grants became surrounded by public land 
that could be settled and purchased from the General Land Office. 

In 1847, Francisco Alviso and Isabella Miranda, his wife, sold their interests in Los 
Vaqueros to Noriega and Livermore, who also owned the Rancho Los Positas to the south 
(Land Case #79:41). Livermore and Noriega filed a claim for Los Vaqueros and Los 
Positas in February 1852. Noriega also hired an attorney to settle his land problems. The 
attorney worked out an agreement whereby Livermore received Los Positas, while the 
attorney and Noriega each received a half interest in Los Vaqueros. The attorney sold his 
half interest to William Akenhead, while Noriega sold to Maximo Fernandez. Akenhead 
lost his property because of an unpaid debt; Juan Sunol purchased it at a sheriffs sale. 
Both halves were sold in separate transactions on November 14, 1857. Lorenzo Sunol 
purchased a half interest from Fernandez, and Juan Baptiste Arrambide, Bernardo Altube, 
Bernard Ohaco, and Charles Garat purchased Juan Sunol's half from its current owner, 
Ellen Garat. These two owners lived on the rancho in 1860 and are listed on the census. 

Lorenzo Sunol, a native of Spain, probably lived with his two laborers at the "upper 
adobe" (CCO-450/H) recorded by Hendry and Bowman (1940) and shown as "Sunal" on an 
1873 map (California Geological Survey 1873). On the 1860 U.S. Census Agricultural 
schedule, Lorenzo "Senole" claimed 7,750 acres, of which only 2 were improved. Sunol used 
the land for cattle ranching, Arrambide, Altube, and Ohaco probably lived at the "lower 
adobe" (CCO-470H). Arrambide and Ohaco were French; Altube was Spanish. Altube's 
household included his French wife and infant daughter, Arrambide; three members of the 
Ohaco family; and four other persons of French, Spanish, and Native American descent. 
Of their 8,880 acres, only 5 were improved. The remaining acreage was used to graze 1,280 
head of stock cattle and 50 horses worth $17,750. 

Bernardo Altube and Juan Baptiste Arrambide were among a group of 80 persons 
with Basque surnames who emigrated from Buenos Aires around 1850. The Basques had 
done well in Argentina, and it is this Argentine contingent for whom the term "bascos" as 
a reference to Basques rather than vizcainos is derived (Douglass 1975). Bernardo joined 
his brother Pedro who was already in San Francisco. Five Altube brothers had emigrated 

3-33 



from Spain to Argentina, Pedro leaving in 1845. The brothers prospered in the Argentine 
cattle industry. Prior to 1850, three brothers decided to return to Spain; they liquidated 
their assets, and Bernardo and Pedro emigrated to California (Patterson et al. 1969). In the 
1850s and 1860s, the Altube brothers were partners with other Basque immigrants in 
numerous cattle and dairy operations throughout the state. In approximately 1860, Bernardo 
Altube and Arrambide also had a cattle ranch in Calaveras County (Douglass 1975). 

Although the Land Commission confirmed Robert Livermore and Jose Noriega's 
claim to Los Vaqueros in 1855, and Livermore and Noriega refiled their former transaction 
deeding Los Vaqueros to Noriega, considerable confusion regarding the title to Los 
Vaqueros ensued when Livermore died in 1858. Livermore's wife and eight children 
claimed Los Vaqueros based on a deed to them predating the Noriega transfer (Deeds 
2:156-157). Similarly, each of grantee Antonio Higuera's four children inherited one-quarter 
of their father's interest, which was said to be one-third of the entire rancho (Deeds 8:160), 
while the remaining two-thirds were claimed by Alviso and Miranda. Meanwhile, Lorenzo 
Sunol and the Arrambide partnership each claimed a half interest and resided on the 
rancho. 

By about 1860, various parties held deeded interests totaling over 200% of the Los 
Vaqueros rancho, half of these claims being in the hands of Livermore's heirs and Noriega's 
assignees and the rest held by descendants of the 1,844 grantees. Arrambide, Altube, and 
Ohaco sold their half interest in 1863 to a San Franciscan who quickly transferred the 
property to Louis Peres and Pedro Altube, Bernardo's brother. Peres and Altube gradually 
purchased the interests of eight of Livermore's heirs and of Alviso. When Altube sold his 
interest to Peres in 1880, it purported to cover the entire 17,752-acre rancho (Deeds 39:282). 
During the same period, a wealthy Martinez family, the Blums, bought out Miranda and 
Higuera's heirs. 

The public land surrounding Los Vaqueros was surveyed in the 1860s and 1870s, 
opening the area to permanent settlement. An individual could obtain a maximum of only 
320 acres from the federal government, a very small holding in comparison to the thousands 
of acres that made up neighboring Mexican land grants. It was not until the early 1870s that 
patentees filed claims to government land surrounding Los Vaqueros, using a combination 
of homestead and cash entry patents to obtain small 320-acre ranches (e.g., CCO-562H, 
CCO-563H). The settlers in the hilly area west of the grant were predominantly Califomios 
and Mexican immigrants. Many of these families lived on their land through 1880 but 
disappeared from the area by 1900. The public land between the Los Meganos and Los 
Vaqueros land grants and to the east of Los Vaqueros was settled by Americans and 
Northern European immigrants. The descendants of some of these settlers kept their 
holdings until the second half of the twentieth century. 

Meanwhile, the nature of stock raising was changing. During the Mexican period, 
cattle had been raised primarily for the hide and tallow trade because there was no market 
for large quantities of beef. The California Gold Rush, however, created a huge demand 
for meat, and the orientation of ranchers changed dramatically during the cattle boom of 
1850-1860. Improved cross-bred stock replaced the original Spanish breeds (Burcham 1957, 
1961). The necessity of range improvements became immediately obvious when almost two 



3-34 



million head of cattle perished in the floods of 1861-1862 and the subsequent drought of 
1863-1864. The first range improvements occurred due to this demise, after which ranchers 
planted various forage crops as a supplement to the natural vegetation (Burcham 1975). In 
addition, many ranchers began raising sheep from the 1870s, finding these animals better 
adapted to California's semi-arid climate (Burcham 1956, 1957, 1961). 

The Altube brothers, and eventually the Arrambide and Garat families, "feeling 
crowded" by the changes in California, moved their cattle enterprises to Nevada. In 1871, 
Bernardo and Pedro Altube sold most of their California holdings; purchased 3,000 head 
of cattle in Mexico; and drove them to eastern Nevada where they settled. The Altubes 
created a thriving "cattle kingdom" on their Spanish Ranch (Patterson et al. 1969). 

Lx)uis Peres remained in California, where he is listed at Los Vaqueros on the 1880 
census with his wife and young daughters, their governess, his invalid brother, three farm 
laborers, and a Chinese cook. Peres and his employees were French. By this time, the land 
grant had been divided into at least five rented parcels. The family of one of the lessees. 
Sylvan Bordes, lived on the grant through the 1930s. 

In 1881, a mortgage taken out on Los Vaqueros by Peres and Altube was 
approaching foreclosure. At that time, the interests in the rancho that had been sold to 
Peres and Altube and to Blum were broached, and a settlement was suggested by the 
mortgage holder who had purchased Akenhead's interest to the property at a probate sale 
in 1868 (Deeds 15:428), despite the sale by Sheriffs Deed of this same property more than 
10 years before (Deeds 5:196). Peres and Altube's mortgage "purported to cover the entire 
Rancho Canada de Los Vaqueros, whereas Simon Blum claims title as owner of two thirds 
of said Rancho" (Deeds 39:425). In 1881, Peres sold his claim to Charles McLaughlin, and 
in 1889 Blum sold his interest to Mary Crocker, McLaughlin's heir (Fredrickson 1982). 
Other claimants, including Lorenzo Sunol, continued to contest Blum's claim until the issue 
was settled in court in 1889 (Deeds 57:356; Patents 4:124). 

A third factor entered into the disposition of land surrounding Los Vaqueros. In 
1862 and 1864, Congress passed acts to aid the construction of a railroad and telegraph line 
from the Missouri River to the Pacific Coast. The Western Pacific Railroad was promised: 

every alternate section of Public Land designated by odd numbers to the 
amount of ten alternate sections per mile on each side of said Railroad on the 
line thereof, and within the limits of twenty miles on each side of said road, 
not sold, reserved or other disposed of by the United States, and to which a 
Preemption or Homestead claim may not have been attached at the time the 
line of said road is definitely fixed (Patent 1:237). 

On February 1, 1870, it was reported that the telegraph line and railroad had been 
completed and equipped, and Charles McLaughlin, land agent and contractor for the 
Western Pacific Railroad, selected 111,527.57 acres of public land (Patent 1:237-251), 
including many of the odd-numbered sections surrounding the Los Vaqueros land grant. 



3-35 



McLaughlin subcontracted a portion of his contract to Jerome B. Cox, who never 
received full payment for his work. For 20 years. Cox fought McLaughlin in the courts. 
Each time a judgment awarded payment to Cox, McLaughlin's attorneys appealed and the 
decision was overturned. In frustration, poverty, and despair, Cox killed McLaughlin in 
1883. Cox claimed self defense, with public opinion weighing so heavily in his favor that all 
charges were dropped at the preliminary hearing. At the time of his death, Charles 
McLaughlin was the second largest landholder in California, following only Leland Stanford. 
Kate McLaughlin outlived her husband by 5 years and left the large estate to her two nieces, 
Kate Dillon and Mary Crocker (Williams n.d.). 

Following the final resolution of Los Vaqueros title disputes in 1890, Mary Crocker 
divided the property into a greater number of ranches that she leased out to tenants who 
practiced more intensive forms of agriculture. In 1929, Los Vaqueros was divided into 13 
leased units (e.g., CCO-426H, CCO-569H). Many of these ranchers were immigrants from 
France, Italy, and Portugal. Some families continued their lease agreements on the property 
for over 30 years, passing them from parents to sons along with livestock and personal 
property on retiring (e.g.. Miscellaneous Records 12:359). These tenant ranchers and the 
few surrounding owner-occupiers practiced mixed agriculture. They raised a little grain, 
wheat, and hay, and ran small dairy or beef cattle herds, sheep, pigs, horses, and poultry. 
In 1924, for example, the Fragulia family owned approximately 60 cows, 27 horses, 150 
sheep, and 25 pigs (Miscellaneous Records 12:359). 

Although some of the Californio-Mexican population remained in 1900, recent 
immigrants from the Azores now resided in the former public land in the Black Hills to the 
west of the Los Vaqueros grant. The parcels of the original patentees generally had not 
been consolidated, but the Azorian ranchers owned or leased many noncontiguous 160- to 
320-acre parcels to form larger holdings. 

O.L. Starr purchased a 7,883-acre parcel from the Mary Crocker estate in 1935 
(Official Records 396:16). At that time, the Vasco Road property was leased by an Italian 
family who lived on the west side of Kellogg Creek. Starr built his complex nearby on the 
east side of the creek, and the earlier ranch complex, including the site of an 1850s adobe, 
fell into ruins (CCO-470H). Starr made many improvements, including a new ranch house, 
bams (CCO-449/H, CCO-450/H), and water systems (CCO-451H, CCO-467/H). Starr 
raised cattle and sheep on the property, but he hired others to do this work while he 
concentrated on the early development of the caterpillar tractor. His father-in-law, 
Abraham Holt, began experimenting with track-laying tractors around 1904. After World 
War I, Holt, Starr, and Bess (formerly of Bess Tractor in San Leandro) merged and formed 
the Caterpillar Tractor Company. Starr, "a natural inventor", built the machine shed at the 
ranch and experimented with the Caterpillar. Starr and his men test drove tractors on the 
ranch (Ladd pers. comm.). Starr's ranch was held up as model of efficiency (Purcell 
1950:198): 

Starr's cattle ranch on the Vasco is a model institution, equipped with 
caterpillar tractors and other modem farm machinery. Home buildings of 
Spanish architecture and landscaped grounds, spacious fireproof storage sheds 
with concrete floors, generating power plant and water system are but a few 



3-36 



of the features of the 8,000 acre estabHshment that is conducted on an 
efficient business basis. 

Mrs. Edith Ordway bought this portion of the Starr Ranch in 1948 (Official Records 
1168:195). Ordway razed Starr's residence and had a new residence built on its foundation. 



Charles and Sue Nissen also purchased Los Vaqueros acreage from Crocker's heirs 
as an investment in the 1930s. The Nissens continued to reside in Livermore, where they 
had a hay and grain business and leased to Crocker's tenants, making improvements to the 
properties, including at least one residence (Nissen pers. comm.). The Nissen tenants 
moved their dwellings out of Los Vaqueros when the property was sold following the 
Nissens' deaths. 



3-37 



LxK Vaqueros Outline History 
(within Land Grant Only) 



Year 


Name 


1840 


Francisco Alviso 




Antonio Hiquera 




Manuel Miranda 


lg47 


Robert Livermore, Jose Noriega 


1857 


Loren/o Sunol 




Juan Baptiste Arrambide, 
Bernardo Altubc, Bernardo 
Ohaco 




Charles Carat 


1860s 


Pedro Vasco, Pierre Pederio 


1863 


Louis Peres, Pedro Altube 


1875 


John Elliott 


1880 


Louis Peres 



Association 



Sylviui and Minnie Bordes family 



Frank Viala 



Johnson and Mattie Righter 



Fred and Katie Dickhoff 



Grantee, possibly resident at Upper Adobe, 
CCo-450/H 

Grantee, possibly resident at Upper Adobe, 
CCo450/H 

Grantee, possibly resident at Upper Adobe, 
CCo-450/H 

Alviso sells grant to Livermore and Noriega 

Purchase half interest b Los Vaqueros; lives 
at Upper Adobe in 1860 

Partners purchase half interest in Los 
Vaqueros lives at Lower Adobe; CCo-470H in 
1860 

Purchase half interest in Los Vaqueros; lives 
in San Francisco; partner 

Reportedly live at Upper Adobe 

Purchases half interest of Arrambide et al. 

Purchases part of Los Vaqueros at county 
line; Uves in Alameda County near Brushy 
Peak, outside of project area 

Altube sells interest; Simon Blum also claims 
Los Vaqueros; Louis Peres Uves at 470H with 
his wife, daughters, governess, farm workers, 
Chinese cook, and brother; Peres and his 
workers are French 

Lives on Los Vaqueros grant (426H) with 
daughter, visiting relatives, and farm workers; 
Mrs. Bordes was a Barnes from site nearby; 
they live on site through ca. 1940; French 
(possibly Basque) 

Lives on Los Vaqueros grant with school 
teacher, disabled woman, and farm worker; 
Viala is French 

Live on Los Vaqueros grant with two children, 
farm worker, and servant; Righter is from 
New Jersey 

Live at 453H with their three children and 
hired hand; Prussian 



3-38 



Los Vaqueros Outline History 
(Within Land Grant Only) 

Continued 



Decade 



Name 



Association 



Louis Commey household 



1889 



1900 



1900 
1910 



Charles McLaughlin 



Mary Crocker (Kate Dillon) 



Thomas and Catherine Perata 
family 

Andrew and Mary Fragulia 
family 

John and Mary Silva family 



Antone Rose family 

Anna Connolly and children 

Frank Raffette sheep camp 

Joe Jason and family 

John and Angela Bonfante family 

Nolan and Lillie Coats family 





Peter Dario 


1917 


Charles and Sue Nissen 


1920s 


C. Rock 


1921 


John and Mary Vallerga 



Lives at 569H with Chinese cook and five 
hired hands; Commey is from Missouri 
household on grant with four ranch hands, 
cook, and baker (Alexander Peres); four from 
France, one from Italy, and one from Azores 

Purchases Peres interest; McLaughlin very 
wealthy resident of San Francisco 

McLauhlin heirs purchase Blum's interest; 
Lorenzo Sunol claim settled in court; Crocker 
very wealthy resident of San Francisco 

Leases tenant ranch at CCo-427H from prior 
to 1990 until ca. 1908; Italian 

Leases tenant ranch at CCo-448H from prior 
to 1900 to after 1935; Italian 

Leases tenant ranch at CCo-470H; Lower 
Adobe from prior to 1900 to after 1910; may 
have followed directly after Peres; Portuguese 

Lease tenant ranch, CCo-445H, from prior to 
1900 to before 1928; Portuguese; Waymouth 
place prior to 1900 

Leases tenant ranch, CCo-546H, from prior to 
1900; Irish widow 

Leases tenant ranch, CCo-446H from prior to 
1900 until prior to 1928; French 

Leases tenant ranch, possibly ALa-536H 

Lease CCo-427H from ca. 1908 to ca. 1928; 
Italian 

Leases 569H; lived with grown son; 
Califomian 

Leases property on grant; lives with widowed 
mother and sister; parents were French; 
possibly Upper Adobe 

Purchases Elliott's property from his estate 

Reportedly lives at Upper Adobe (1921-27) 

Lease tenant ranch at CCo-453H until prior to 
1935; previous tenants include Joe Medina 
and Dickhoff 



3-39 



Los Vaqueros Outline History 
(Within Land Grant Only) 

Continued 



Decade 



Name 



Assoaation 



1928 



1935 



1936 
1948 



John and Palmira Cardoza 

Stanley Cabral 
Frank N. Cabral 
Frank Ferrario 

Redin 

Sam Lasuretta 
Oscar Starr 



Charles and Sue Nissen 
Edith Ordway 



Lease CCo-427H from 1928 to an imknown 
date 

Leases CCo-470H, resided there 

Leases CCo-445H, CCo-446H, lived elsewhere 

Leases CCo-569H through 1935; prior tenants 
mclude WiUiam Souza, Nolan Coats, Commey 

Leases ALa-536H; raises sheep; possibly 
Basque 

Leases tenant ranch at CCo-453H 

Purchases 7,883-acre parcel from Crocker 
estate, including Uppver and Lower Adobe; 
builds new complex at Lower Adobe and 
other improvements 

Purchase portion of Crocker estate 

Purchases portion of Starr Rjuich, including 
Upper and Lower Adobe; built new residence 
at Upper and Lower Adobe 



3-40 



CITATIONS 



Printed References 



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Road, Lafayette, California. Ms. on file, California Archaeological Inventory, 
Northwest Information Center, Sonoma State University, Rohnert Park. 

. 1991. Archaeological recormaissance of the Easton Property (Parcel 85), 



Contra Costa County, California. Prepared for Castle Construction Company, 
Concord, California. Ms. on file, California Archaeological Inventory, Northwest 
Information Center, Sonoma State University, Rohnert Park. 

Banks, P., R. I. Orlins, H. McCarthy, M. E. Basgall, J. Blackard, P. D. Bouey, R. J. Jackson, 
B. Roth, and P. D. Schulz. 1984. Final report Walnut Creek project: test excavation 
and evaluation of site CA-CCo-431, Contra Costa County, California. Prepared for 
the U.S. Army Corps of Engineers, Sacramento District. 

Beardsley, R. K., 1954. Temporal and areal relationships in central California archeology. 
University of California Survey Reports 24-25. Berkeley. 

Beck, W. A., and Y. D. Haase. 1974. Historical atlas of California. Norman: University 
of Oklahoma press. 

Bennyhoff, J. A. 1968. A Delta intrusion to the bay in the late middle period in central 
California. Paper presented at the annual meeting of the Southwestern 
Anthropological Association and the Society for California Archaeology, San Diego. 

Bennyhoff, J. A., and R. E. Hughes. 1987. Shell bead and ornament exchange networks 
between California and the western Great Basin. Anthropological papers of the 
American Museum of Natural History, Vol. 64, New York. 

Bramlette, A. G., M. Praetzellis, A. Praetzellis, K. M. Dowdall, P. Brunmeier, and D. A. 
Fredrickson. 1991. Archaeological resources inventory for Los Vaqueros Water 
Conveyance alignments. Contra Costa County, California. Sonoma State University 
Academic Foundation, Inc. Prepared for Jones & Stokes Associates, Inc. 
Sacramento. Ms. on file, California Archaeological Inventory, Northwest Information 
Center, Sonoma State University, Rohnert Park. 

Bramlette, A. G., M. Praetzellis, D. A. Fredrickson, and A. Praetzellis. 1991. A summary 
inventory of archaeological resources within the Los Vaqueros Project area, Alameda 
and Contra Costa Counties, California. Sonoma State University project area, 
Alameda and Contra Costa Counties, California. Sonoma State University Academic 
Foundation, Inc. Prepared for Jones & Stokes Associates, Inc., Sacramento. Ms. on 



3-41 



file, California Archaeological Inventory, Northwest Information Center, Sonoma 
State University, Rohnert Park. 

Burcham, L. T. 1957. California range land: an historic-ecological study of the range 
resource of California. California Department of Natural Resources, Division of 
Forestry, Sacramento. 

. 1961. Cattle and range forage in California: 1770-1880. Agricultural history 



35(3):140-149. 

California Geological Survey. 1873. Map of region adjacent to Bay of San Francisco. On 
file, map room, DOE library. University of California, Berkeley. 

Callaghan, C. A. 1982. Ethnohistory study. In Los Vaqueros: a cultural resource study, 
edited by Davis A. Fredrickson. Sonoma State University Academic Foundation, Inc. 
Submitted to California Department of Water Resources, Sacramento. 

Contra Costa Water District. 1992. Los Vaqueros Project water rights hearing. A 
collection of ethnographic studies prepared for State Water Resources Control Board 
water rights hearing. 

Cook, S. F. 1976. The population of the California Indians. 1769-1970. University of 
California Press, Berkeley, CA. 

DeNeir, F. L. 1928. Robert livermore and the development of Livermore Valley to 1860. 
Unpublished Master's thesis, History Department, University of California, Berkeley. 

Douglass, W. 1975. Amerikanuak: Basques in the New World. University of Nevada 
Press, Reno, NV. 

Elsasser, A. B. 1978. Development of regional prehistoric cultures. In Handbook of the 
North American Indians, Volume 8, California. Edited by Robert F. Heizer. Smithsonian 
Institution, Washington, D.C. 

Gerow, B. A. 1968. An analysis of the University village complex, Stanford University, 
Stanford. 

1974. Comments on Fredrickson's "Cultural Diversity". The Journal of 



California anthropology l(2):239-246 

Heizer, R. F. 1949. The archaeology of central California, I: the early horizon. University 
of California Anthropological Records 12(1): 1-84. 

Fredrickson, D. A. 1965. Recent excavations in the interior of Contra Costa County, 
California. Sacramento Anthropological Society Papers 3:18-25. 



3-42 



. 1966. CCo-308: The archaeology of a Middle Horizon Site in Interior Contra 

Costa County, CaUfornia. Unpubhshed Master's thesis. Department of Anthropology, 
University of California, Davis. 

1973. Early cultures in the North Coast Ranges, California. Unpublished 



Ph.D. dissertation. Department of Anthropology, University of California, Davis. 

. 1974a. Cultural diversity in early central California: a view from the North 



Coast Ranges. Journal of California Anthropology 1:41-53. 

. 1977a. Prehistoric exchange systems in Central California: A Contra Costa 
example. Paper prepared for Archaeology of the Central Valley, Cosumnes River College 
Symposium, Sacramento. 

. 1980. Archaeological overview and research design for the Walnut Creek 
project. Contra Costa County, California. Prepared for the U.S. Army Corps of 
Engineers, San Francisco District, San Francisco. 

. 1986. A review of the cultural resources evaluation of Sections 25 and 30, 
Howden Wind Parks, Inc., Vasco Road Area, Contra Costa County, California. Sonoma 
State University, Academic Foundation, Inc. Rohnert Park, California. Ms. on file, 
California Archaeological Inventory, Northwest Information Center, Sonoma State 
University, Rohnert Park. 

Hendry, G. W., and J. N. Bowman. 1940. The Spanish and Mexican Adobes and other 
buildings in the nine San Francisco Bay Counties: 1776 to about 1850. Ms. on file. The 
Bancroft Library, University of California, Berkeley. 

King, C. 1979. Archaeological investigation of two archaeological sites (California-CCo-385 
and California-CCo-386) on a 60 acre parcel located on Lone Tree Drive, City of 
Antioch. Ms. on file, California Archaeological Inventory, Northwest Information Center, 
Sonoma State University, Rohnert Park. 

King, T. F. 1974. Flight to new pidgeonholes: comments on Fredrickson. The Journal 
California Anthropology l(2):233-238. 

Kroeber, A. L. 1962b. Two papers on the aboriginal ethnography of California. The 
nature of land holding groups in aboriginal California. Berkeley. University of California 
Archaeological Survey Reports, 56:21-58. 

Levy, R. 1978b. Eastern Miwok. In California, edited by Robert F. Heizer. Handbook of 
North American Indians, vol. 8. Smithsonian Institution, Washington, D.C. 

Lillard, J. B., and W. K. Purves. 1936. The archeology of the Deer Creek-Cosumnes Area. 
Sacramento Junior College Bulletin 1, Sacramento. 



3-43 



Lillard, Jeremiah, B., Robert F. Heizer. and Franklin Fenenga. 1939. An introduction to 
the archeology of Central California. Sacramento Junior College, Bulletin 1, Sacramento. 

Miller, J., M. Rudo, and K. Rueve. 1977. Report on two burials at the north end of the 
Hotchkiss Tract on the San Joaquin Delta. Ms. on file, California Archaeological 
Inventory, Northwest Information Center, Sonoma State University, Rohnert Park. 

Milliken, R. 1982. An ethnographic study of the Clayton Area, Contra Costa County, 
California. In Cultural Resource Evaluation of Keller Ranch, Clayton, California, Part 
II. Holman and Associates, San Francisco. 

Moratto, M. J. (ed.) 1984. California archaeology. Academic Press, New York. 

Moss, J., and R. Mead. 1967. Salvage report on CCo-311 (Jackson Ranch, Danville 

Boulevard at Stone Valley Road, Alamo, California). Ms. on file. California 

Archaeological Inventory, Northwest Information Center, Sonoma State University, 
Rohnert Park. 

Parkman, E. B. 1977. Pleasanton Meadows: A site summation. Ms. on file. California 
Archaeological Inventory, Northwest Information Center, Sonoma State University, 
Rohnert Park. 

Pastron, A. G. 1979. Subsurface archaeological research at 4-CCo-30, Contra Costa 
County, California. Ms. on file, California Archaeological Inventory, Northwest 
Information Center, Sonoma State University, Rohnert Park. 

Patterson, Edna B., Louis A. Ulph, and Victor Goodwin. 1969. Nevada's Northwest 
Frontier. Western Printing and Publishing Co., Sparks, NV. 

Ragir, S. R. 1972. The early horizon in Central California prehistory. University of 
California Archaeological Research Facility, Contributions 15. Berkeley. 

Smith and Elliot. 1879. Illustrations of Contra Costa County, California with historical 
sketch. Smith & Elliot, Oakland. 

Sonoma State University Academic Foundation, Inc. 1992. Evaluation, request for 
determination of eligibility, and effect for the Los Vaqueros Project, Alameda and Contra 
Costa Counties, California. Prepared by Sonoma State University Academic Foundation, 
Rohnert Park, CA. 

Wiberg, R. S. 1984a. A cultural resource reconnaissance of portions of Souza and 
Vaqueros Farms Properties, Contra Costa County, California. Ms. on file, California 
Archaeological Inventory, Northwest Information Center, Sonoma State University, 
Rohnert Park. 



3-44 



Personal Communications 

Fredrickson, D. A, 1992. Personal communication. 

Heizer, R. F. 1977b. Letter to Parkwan responding to summation of Pleasanton Meadows 
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Ladd, S. 1992. Telephone conversation - January 27, 1992. 

Nissen, G. 1992. Telephone conversation - January 27, 1992. 



3-45 



3-46 



Attachment 4. Fish and Wildlife Coordination Act Compliance 



4-1 



4-2 



Table of Contents 



Page 

Introduction 4-5 

7.1 Terrestrial Resources Recommendations 4-5 

7.2 Special-Status Plant Recommendations 4-11 

7.3 Special-Status Wildlife Recommendations 4-15 

7.4 Special-Status Reptile And Amphibian Recommendations 4-19 

7.5 Special-Status Fish Recommendations 4-22 

Citations 4-24 



4-3 



4-4 



Introduction 



This attachment presents Reclamation's responses to recommendations presented by the U.S. Fish 
and Wildlife Service (USFWS) in the Fish and Wildlife Coordination Act (FWCA) report (U.S. Fish and Wildlife 
Sen/ice 1993). The full report is available for review at Reclamation and CCWD offices. 

Reclamation's analyses and responses to recommendations are organized in the same order and 
major categories as the FWCA report. Comment numbers within each section refer to the number in the 
FWCA report, except that numbers for subchapters (e.g., 7.3) were combined with recommendation numbers 
for clarity (e.g., 7.3.1, 7.3.2). The text of each USFWS recommendation is presented first, followed by 
Reclamation's response. 

Many of the recommendations in the report are identical or similar to measures that the Contra 
Costa Water District (CCWD) has already adopted or has proposed in the draft Stage 2 Environmental 
Impact Report/Environmental Impact Statement (EIR/EIS) (Contra Costa Water District and U.S. Bureau of 
Reclamation, Mid-Pacific Region 1992) (see "Impact Conclusions and Environmental Commitments", Chapter 
19). Reclamation has rejected or modified some of the recommendations proposed in the FWCA report. 

The bases for Reclamation's decisions are specified in the following specific analyses and 
responses. 

7.1 Terrestrial Resources Recommendations 



Recommendation 7.1.1 

Develop, in cooperation with the Sen/ice and DFG as appropriate, additional performance standards 
for measuring the success of wetland and riparian habitat recreation efforts based on actual use of the 
mitigation sites by target species. 

Analysis. CCWD is continuing to incorporate the needs of the wildlife species and communities, 
including evaluation species identified by USFWS, into criteria to evaluate habitat. The needs of the wildlife 
species were explicitly incorporated into the design of wetland and riparian mitigation habitats (Jones & 
Stokes Associates 1992a, 1993a) and into evaluations of wetland and riparian habitat values (Contra Costa 
Water District 1992, Jones & Stokes Associates 1991a). 

CCWD included several evaluation criteria in addition to wildlife species use (e.g., sensitive plant 
species, plant community diversity, and hydrdogic function) in its evaluation of wetland habrtats. This 
approach provides a more complete community-based analysis for wetlands than one strictly focused on 
wildlife species and guilds. 

Response. Reclamation modifies the recommendation to specify that CCWD should proceed with 
project planning based on CCWD's past impact analysis and mitigation planning approaches. Reclamation 
also will add to the recommendation that CCWD continue to work with USFWS to incorporate the needs of 
USFWS evaluation species as appropriate. 



4-5 



Recommendation 7.1.2 

Monitor golden eagle nesting success in areas where eagles could be disturbed by construction, 
reservoir inundation, or recreational development and activities. Eagle nesting success should be nnonitored 
several years before, during, and after such construction, inundation, and development. Should monitoring 
reveal increased rates of abandonment of nests containing eggs or unfledged young, or a decrease in the 
number of young fledged per nest, remedial actions should be taken. Possible remedial actions should be 
developed in advance, in cooperation with the Service and DFG. 

Analysis. Monitoring of all golden eagle nest sites in the Kellogg Creek watershed Is unnecessary 
because some nest sites are located far from any potential disturtjance. Also, some potential disturbance 
by recreation development would not occur for 10-20 years. CCWD has already proposed to monitor nest 
sites that could be affected by construction activities and to undertake appropriate measures as required 
(mitigation measure 8-6 in the draft Stage 2 EIR/EIS). 

The abandonment of any golden eagle territory is considered unlikely because only a small amount 
of habitat would be affected (maximum loss is 22% in one territory) and enhancement of watershed habitat 
(elimination of ground squirrel poisoning and reduced grazing intensity) is expected to offset the loss of 
habitat acreage. Previous studies (Jones & Stokes Associates 1989, 1991b) show that golden eagles move 
their nest sites regularly in the watershed. Also, golden eagles' tendency to use typical oak trees as nest 
sites ensures many alternative nest sites are available. Therefore, eagles are likely to be resilient to 
anticipated levels of disturtaance. 

Response. Reclamation modifies the recommendation to state that eagle pairs with nests near the 
inundation zone sfiall be monitored for several years before, during, and after inundation, and that impacts 
of future recreation facilities be evaluated and monitored when facilities or recreation uses are specifically 
planned. If potential impacts are identified, remedial measures will be developed in cooperation with USFWS 
and DFG. This modified recommendation is consistent with existing commitments in the Stage 2 EIR/EIS. 



Recommendation 7.1.3 

Restrict additional development within 0.5 mile of any active golden eagle nest. While this distance 
may be modified based on the particular circumstances (e.g., topography) of each nest site and potential 
disturbance, it should be treated as a general guideline and any modifications as exceptions. Establishment 
of suitably large buffers where eagles may be disturbed by recreational activities is especially important; 
where disturbances are ongoing, predictable, and relatively constant, buffers need not always be as large. 

Analysis. This recommendation is not supported by scientific evidence and information obtained 
in studies at the project site (Jones & Stokes Associates 1989, 1991b) and elsewhere in the literature. 
Eagles currently nest successfully within 0.5 mile of Vasco Road, residences, fire roads, and other 
constructed features. The need for protection during recreation planning Is best determined by site, based 
on the specific types of disturbance (e.g., noise levels, duration, and timing), protection provided by 
topographic and vegetation screening, and individual tolerance of birds. 

Response. This recommendation is not reasonable or justifiable. The recommendation is 
unacceptable because it is unduly restrictive and unreasonably costly and offers no concomitant benefits. 

Reclamation modifies the recommendation to specify that when future recreation development is 
proposed in potential golden eagle nesting and foraging habitat, CCWD will evaluate effects on a site- and 
project-specific basis during project planning and provide appropriate mitigation to reduce impacts as much 
as possible. Mitigation measures may include establishment of buffers and seasonal restriction on use of 
facilities. 



4-6 



Recommendation 7.1.4 

Initially restrict livestock grazing in wetland and oak habitats to the period from November 1 to 
June 1 or 1 5, depending on the growing season. The impacts of this seasonal restriction on other resources 
should be monitored; if this monitoring reveals significant adverse impacts on, for example, erosion or fire 
control, the seasonal restrictions may be modified. Modifications should be made after further consultation 
with the Service. 

Analysis. Grazing has occurred in oak and wetland habitats for a substantial period of time. 
CCWD's land management will most likely result in reduced grazing in wetland and oak habitats. CCWD 
will continue to review grazing levels in all habitats on a site-specific basis to determine whether adjustments 
are necessary. Grazing must be balanced with the need to prevent erosion and to minimize supplemental 
feeding in winter, and the need to maintain appropriate levels of grazing to minimize wildfire risks. Strictly 
limiting grazing in wetland and oak habitats to November 1-June 1 (or June 15) may not be appropriate 
given these requirements. 

Response. Reclamation modifies the recommendation to specify that CCWD should consider 
habitat values in its grazing program and should evaluate and implement practices that enhance oak and 
wetland habitats, consistent with other management needs for biological resources (e.g., kit fox) and other 
resources (e.g., fire control and water quality protection). These issues will be addressed in the watershed 
management plan that CCWD has committed to prepare. Specific restrictions on the season of grazing will 
be addressed in this later plan. 

Recommendation 7.1.5 

Consider, as an enhancement measure, discontinuing dryland farming. Restoration of dry farmed 
areas to annual or native grasslands would benefit kit foxes, salamanders, small mammals, and raptors. If 
new stock ponds are created in these reconverted areas, additional habitat would be developed for a variety 
of amphibians, small mammals, and migratory birds. As with other stock ponds, they should be no more 
than 0.5 mile apart. To discourage use by bullfrogs and introduced fish, ponds should be designed to dry 
out by July or August each year. 

Analysis. CCWD's acquisition and proposed grazing management practices and the elimination 
of widespread rodenticide use will substantially improve the condition of annual grasslands in the watershed. 
CCWD is committed to maintaining agricultural uses of the watershed. The CCWD Board of Directors 
adopted findings for the Stage 1 EIR for the Los Vaqueros Project and Resolution 88-45, which call for 
continued agricultural operations in the watershed. If, in the future, CCWD does not receive requests from 
lessees to continue dryland farming, CCWD will consider allowing these areas to revert naturally to 
grasslands. In addition, courts may limit the interests that CCWD can acquire, which may preclude CCWD's 
ability to affect agricultural operations. 

Response. Reclamation rejects this recommendation for the reasons described above. 
Construction of additional concentrated stock ponds in the area as discussed in this recommendation would 
be impractical. Jones & Stokes Associates' analysis of pond construction feasibility indicates that 
opportunities to construct new ponds are limited because existing ponds in the area have largely used the 
available precipitation and runoff at the project site. 

Recommendation 7.1.6 

Retain ownership of all mitigation ponds to be created or enhanced along the relocated Vasco Road. 
Alternatively, CCWD or Reclamation could acquire conservation easements requiring that the ponds be 
maintained and used as described in the mitigation plan. 



4-7 



Analytl*. The stock ponds to be replaced and enhanced along the relocated Vasco Road have 
been under private ownership and have had no perpetual protection or management. The new stock ponds 
would be replaced before road construction and will provide adequate habitat values to replace the affected 
ponds. CCWD will not retain ownership of lands along all portions of the relocated Vasco Road. Two of 
the three ponds to be created and one of two ponds to be acquired will be owned by CCWD. Ponds to be 
constructed on lands acquired by CCWD will receive greater protection than the affected ponds currently 
receive; those that will remain in private ownership will receive the same low level of protection as existing 
ponds on private lands. 

Response. Reclamation rejects this recommendation because the planned mrtigation is sufficient, 
and acquiring ownership of or easements for the remaining ponds would be unreasonably costly. 

RecommerKlatlon 7.1.7 

Acquire additional acreage for valley oak mitigation. The Service has determined that about 394 
acres would be needed to compensate for lost values of valley oak woodlands. CCWD, in cooperation with 
DFG and the Service, should develop additional areas within or adjacent to the watershed for valley oak 
woodland as well as oak savanna restoration. The horticultural methods, success criteria and monitoring 
periods described within the Oak Mitigation and Restoration Plan appear to be adequate. 

Analysis. CCWD will, based on agreements with USFWS and Reclamation, plant 375 acres of valley 
oak habitat, plus approximately 19 acres for valley oak habitat that may be affected by future recreation 
facilities. 

Response. Reclamation modifies this recommendation to state that CCWD will recreate up to 394 
acres of valley oak habitat on lands currently planned to be under CCWD ownership and taking into account 
the availability of suitable soils, adequate water supplies for initial irrigation, and depth to the water table. 

Recommendation 7.1.8 

Develop, in consultation with the Service and DFG, a mitigation and monitoring plan for impacts on 
blue oak woodlands. Although CCWD intends to purchase and protect more than 4,000 acres of existing 
blue oak woodlands, additional acreage is needed to mitigate for the 67 acres that will be lost due to 
permanent impacts from the project. Conceptually the blue oak plan should be similar to the valley oak 
mitigation plan. In addition, a management plan for this habitat type should be developed to assess the 
current condition in the project area and develop management measures to enhance and expand this habitat 
type. Poor recruitment appears to be a major factor affecting the decline of blue oak woodlands. The effect 
of current and proposed grazing practices on the health and recruitment of blue oaks should be assessed 
and modified if necessary. Additionally, the watershed should be evaluated in the same manner as for valley 
oaks to assess the historic extent of blue oak distribution and encourage restoration of historic blue oak 
habitat. 

Analysis. CCWD has committed to avoiding blue oaks during recreation development as a part of 
its conceptual recreation (jian. Avoidance appears feasitjie, given the scattered nature of blue oaks in 
development areas identified in the conceptual plan If future site planning indicates that blue oaks will need 
to be removed, appropriate mitigation will be developed as part of that future planning process. 

A loss of 20 acres of blue oak woodland, representing a loss of less than 0.5% of the blue oaks 
present at the project site, is expected from implementation of the project. Implementation of the project 
would also result in the purchase and protection of more than 4,000 acres of iDlue oak woodland. Habitat 
enhancement for the blue oak community will be accomplished by reducing grazing pressure on the entire 
watershed. Providing this enhancement over the entire watershed will offset the relatively small habitat loss 



4-8 



now determined for the project. However, Reclamation and CCWD have agreed to implement this 
recommendation with minor modifications as described below. 

Response. Reclamation modifies this recommendation to state that CCWD will recreate 
approximately 20 acres of blue oak habitat to replace habitat affected by the construction of initial project 
facilities. CCWD will monitor the actual impacts on blue oak woodlands during the project construction. 
CCWD will develop and implement a mitigation plan conceptually similar to the valley oak mitigation plan 
t>ased on actual impacts on blue oaks. Additionally, as part of its overall watershed management plan, 
CCWD will develop measures to enhance blue oak habitat. An evaluation of the historic extent of blue oak 
woodlands will also be conducted. 



Recommendation 7.1.9 

Investigate, in consultation with the Service and DFG, a range of methods to control bullfrogs within 
the watershed. Control of indivkJual bullfrogs has proven ineffective. 

Analysis. CCWD has committed to controlling bullfrog populations as part of its special-status 
reptile and amphibian mitigation plan (Jones & Stokes Associates 1992a). CCWD will continue to work with 
DFG and USFWS to determine appropriate control methods. 

Response. Reclamation accepts this recommendation. It is consistent with the Stage 2 EIR/EIS 
and current mitigation plans. This recommendation will be implemented through mitigation measures 7-6 
and 8-10. 



Recommendation 7.1.10 

Consider excluding stock ponds and wetlands from cattle grazing wherever practicable. Pipelines 
and troughs could be used to supply water to cattle outside of wetland areas. We suggest that Reclamation 
and CCWD develop a trial program at several ponds where the benefits of cattle exclusion could be 
evaluated; if monitoring reveals significant benefits without adverse costs to other resources, the program 
could be expanded to other ponds and wetlands. 

Analysis. Wetland mitigation sites will be fenced to exclude or control grazing. Certain existing 
and created stock ponds proposed for special-status reptile and amphibian mitigation will also be fenced. 
Reclamation believes that reduced grazing pressures under CCWD land management will improve conditions 
at existing wetlands and stock ponds. 

Response. Reclamation modifies this recommendation to state that designated wetland mitigation 
sites will be fenced to exclude or control grazing, as described in the wetland mitigation plans (Contra Costa 
Water District 1992, Jones & Stokes Associates 1993a). Reclamation believes that CCWD's proposed 
actions to exclude cattle from mitigation areas where wetlands will be created, enhance key wetland sites 
through fencing, and reduce grazing levels throughout the watershed will improve riparian and wetland 
values to offset impacts and provide net benefits. CCWD intends to evaluate grazing effects on these 
habitats as part of its ongoing watershed management practices with the intention of eventually eliminating 
grazing in sensitive habitat areas. 

Recommendation 7.1.11 

Allow only pedestrian and bicycle, not motor vehicle, access from Round Valley preserve to Los 
Vaqueros Reservoir. 



4-9 



Analysis. This recommendation is consistent with CCWD planning. Although access for operational 
use and emergency response may be provided, no public use roads are planned, except near the resen/oir. 

Response. Reclamation accepts this recommendation. No public access through Round Valley 
Is contemplated. 



Recommendation 7.1.12 

Monitor all ponds for fish or bullfrogs. If fish or bullfrog (including pdliwogs) are detected, they 
should be removed by a qualified biologist. Because control of individual fish or bullfrogs is rarely 
successful (although the removal of a rare pioneer may prevent establishment of a population), these ponds 
should be drained and allowed to dry out on a seasonal basis. 

Analysis. CCWD has already proposed to monitor all ponds used for mitigation purposes for fish 
and bullfrogs and to implement control measures If fish or bullfrogs are present. Additionally, CCWD has 
committed to control mosquito problems through careful wetland design and management with water 
drawdown rather than with mosqultoflsh. 

Response. Reclamation modifies this recommendation to state that all ponds used for mitigation 
will be monitored and fish and bullfrogs will be controlled. This recommendation will be implemented 
through mitigation measure 7-6. 



Recommendation 7.1.13 

Not introduce mosquitofish into any water body in the watershed, Including Los Vaqueros Reservoir. 
Response. See response to recommendation 7.4.8 below. 

Recommendation 7.1.14 

Reevaluate implementation of the proposed recreation plan. Elimination of the recreation plan would 
significantly reduce impacts on wildlife habitats by about 450 acres, thus reducing mitigation that would 
otherwise be required. 

Analysis. CCWD is fully aware of the potential impacts of future recreation facilities. The mitigation 
program developed for the biological opinion for the San Joaquin kit fox identified methods of assessing 
and mitigating any future impacts. Additionally, CCWD has proposed stringent development guidelines for 
future recreation facilities that will, when implemented, avoid most potential Impacts. CCWD will continue 
to wori( with USFWS and DFG to address any potential impacts of future recreation development (see also 
recommendation 7.4.7). 

Response. Reclamation accepts this recommendation. CCWD will reevaluate and review its 
conceptual recreation plan to ensure that any potential impacts of future Implementation of the plan are 
minimized. 

Recommendation 7.1.15 

Assess impacts on rock outcrops on the east and west dam abutments. If conflicts in use of rock 
outcrops are likely to occur, the Service and CCWD will negotiate and resolve these conflicts as appropriate. 



4-10 



Analysis. The rock outcrops on the east and west abutments of the proposed dam are not suitat)le 
nesting habitat for raptors, nor do they support habitat for fairy shrimp species. No conflicts or Impacts are 
anticipated. 

Response. Reclamation accepts this recommendation. 

7.2 Special-Status Plant Recommendations 

Recommendation 7.2.1 

Control project construction activities near valley spearscale populations by placing temporary 
barriers around adjacent populations, providing for a 100-foot-wide buffer. Specify in construction contracts 
that such areas will be protected in such a manner. 

Analysis. This recommendation Is consistent with mitigation proposed in the Stage 2 EIR/EIS and 
in the draft construction mitigation plans developed by CCWD. However, because of the proximity of one 
spearscale population to the relocated Vasco Road alignment, maintaining a buffer of 100 feet may not be 
possible. CCWD believes that the planned buffer distances of less than 100 feet are adequate to protect 
the population and the site. This spearscale population will be monitored closely during construction. Other 
protection measures recommended In the FWCA report are already included as project mitigation and will 
be implemented. 

Response. Reclamation accepts the recommendation. It will be implemented through mitigation 
measure 7-14. 

Recommendation 7.2.2 

Reestablish natural land contours, using soil salvaged from the site, on construction areas adjacent 
to valley spearscale populations. 

Analysis. This recommendation Is consistent with mitigation proposed In the Stage 2 EIR/EIS and 
in the draft construction mitigation plans developed by CCWD. 

Response. Reclamation accepts the recommendation. It will be implemented through mitigation 
measure 7-2. 

Recommendation 7.2.3 

Reseed disturbed areas with plant species that occurred in the site prior to disturbance. Species 
that did not previously occur in the project area should not be introduced by mitigation revegetation. 

Analysis. This recommendation Is consistent with mitigation proposed in the Stage 2 EIR/EIS and 
in the draft construction mitigation plans developed by CCWD. 

Response. Reclamation accepts the recommendation. It will be implemented through mitigation 
measure 7-2. 



4-11 



Recommendation 7.2.4 

Mitigate for potential impacts on special status plant species through protection and restoration of 
existing special-status plant sites, at ratios greater than 1:1, rather than attempting to increase apparent 
population numbers at sites adjacent to disturbed sites. 

Analysis. Protection and restoration of existing spearscale populations are not necessary because 
spearscale populations will not be adversely affected by the project. As part of project implementation, 
several populations of spearscale will be purchased and protected. Improved land management practices 
(especially decreased grazing intensity) on these lands are expected to provide some enhancement benefits 
for these populations. 

Response. This measure is modified to specify that mitigation proposed in the Stage 2 EIR/EIS 
and in the wetland mitigation plan (Jones & Stokes Associates 1993a) will b>e implemented. 



Recommendation 7.2.5 

Because future livestock grazing likely will continue to adversely affect spearscale populations and 
their alkaline habitats, develop specific management objectives for spearscale habitat areas regarding 
improvements in or state of vegetative cover, composition, and vigor; in erosion and soil surface 
characteristics; and for hydrological functions. Use protected, undisturbed reference areas to define 
objectives where possible. 

Analysis. This species will not be adversely affected by the project. Development of specific 
management objectives is consistent with the recommendation in mitigation measure 7-1 1 of the Stage 2 
EIR/EIS. However, this mitigation measure is not required because spearscale populations will not be 
adversely affected by the project. 

Response. This measure is rejected as not justifiable because the project will not result in 
detrimental impacts on spearscale populations. 



Recommendation 7.2.6 

Because future livestock grazing likely will continue to adversely affect spearscale populations and 
their alkaline habitats, closely monitor grazing use and effects. Periodically evaluate progress toward 
meeting specific management objectives for valley spearscale habitat areas. 

Analysis. Development of specific grazing management objectives for spearscale populations is 
not required as a mitigation measure because the species will not be adversely affected by the project. 
Spearscale populations within wetland enhancement areas will be monitored to evaluate effects of protection 
from grazing. 

Response. Reclamation modifies the recommendation to specify that CCWD should monitor 
population trends of spearscale in wetland mitigation areas as part of the overall mitigation monitoring 
program. Monitoring in mitigation sites should be quantitative. 

Recommendation 7.2.7 

Because future livestock grazing likely will continue to adversely affect spearscale populations and 
their alkaline habitats, implement other management techniques, such as changing water availability, herding, 
and fencing, if livestock use in these areas continues to prevent substantial improvement in vegetative, soil, 



4-12 



and hydrologic conditions and monitoring shows that spearscale populations and habitat continue to be 
degraded by livestock grazing and management objectives are not achieved. 

Analysis. Implementation of intensive grazing management techniques is not required as a 
mitigation measure because spearscale populations will not be adversely affected by the project. 
Observations made during extensive field surveys in the watershed have documented that reduction in 
grazing intensity benefits spearscale populations (Jones & Stol<es Associates 1989, 1992b). Therefore, it 
appears that reductions in grazing intensity that have already been implemented by CCWD will provide 
substantial enhancement. Because the species is sufficiently abundant in the watershed (i.e., 31 populations 
supporting over 60,000 individuals [Jones & Stokes Associates 19891), more expensive enhancement 
techniques are not justifiable. 

Response. Reclamation modifies the recommendation to state that no mitigation measures are 
required because spearscale will not be affected by the project. Additional, more intensive techniques to 
enhance spearscale and other special-status plant populations should be considered if existing measures 
do not maintain or enhance populations and if measures can be implemented at reasonable cost. 

Recommendation 7.2.8 

Avoid special-status plant populations when siting firebreaks and conducting other fire management 
activities. Develop future fire management plans in consultation with the Service and DFG to ensure that 
special-status plants are not adversely affected by fire management practices. 

Analysis. This recommendation is consistent with mitigation already proposed in the project 
description in the Stage 2 EIR/EIS. 

Response. Reclamation accepts the recommendation. It will be implemented through mitigation 
measure 7-19. 



Recommendation 7.2.9 

Conduct preconstruction surveys at recreation development sites and avoid impacts on identified 
special-status populations. 

Analysis. This recommendation is consistent with mitigation already proposed in the project 
description in the Stage 2 EIR/EIS and CCWD's Recreation Use Suitability and Opportunities Report 
(Jones & Stokes Associates 1991c). 

Response. Reclamation accepts the recommendation. It will be implemented through mitigation 
measure 7-18. 



Recommendation 7.2.10 

Avokj siting high-use facilities within 0.25 mile of special-status plant populations unless other 
features are present that protect the resource from adjacent land use and future facility expansion. 

Analysis. This recommendation is consistent with mitigation already proposed in the Recreation 
Use Suitability and Opportunities Report and is included in the project description in the Stage 2 EIR/EIS. 



4-13 



Response. Reclamation accepts the recommendation. It will be implemented through mitigation 
measure 7-18. 



Recommendation 7.2.11 

Provide design features that eliminate possitjie indirect effects, such as increased runoff, on special- 
status plant habitat areas. 

Analysis. This recommendation is consistent with mitigation already proposed in the Recreation 
Use Suitability and Opportunities Report and is included in the project description in the Stage 2 EIR/EIS. 

Response. Reclamation accepts the recommendation. It will be implemented through mitigation 
measure 7-9. 



Recommendation 7.2.12 

All special-status plant populations should be in controlled-use or no-use areas as defined in 
Jones & Stokes 1991. 

Analysis. This recommendation is consistent with mitigation already proposed in the Recreation 
Use Suitability and Opportunities Report develofjed by GCWD and included in the project description in the 
Stage 2 EIR/EIS. 

Response. Reclamation accepts the recommendation. It will be implemented through mitigation 
measure 7-18. 



Recommendation 7.2.13 

Establish a minimum buffer zone of 200 feet between special-status plant populations and new roads 
and trails. Design trails and roads to minimize effects of increased runoff and erosion on downslope 
populations. 

Analysis. This recommendation is consistent with mitigation already proposed in the Recreation 
Use Suitability and Opportunities Report developed by GCWD and included in the project description in the 
Stage 2 EIR/EIS. 

Response. Reclamation accepts the recommendation. It will be implemented through mitigation 
measure 7-18. 



Recommendation 7.2.14 

Implement measures to avoid or minimize disruption of hydrologic functions and erosion effects on 
valley spearscale habitat areas, including, but not limited to, re-siting trails or elevating trails and paths over 
these areas. 

Analysis. This recommendation is consistent with mitigation already proposed in the Recreation 
Use Suitability and Opportunities Report developed by GCWD. Mitigation options to be considered include 
siting trails outside the functioning watershed of special-status plant populations or installing protective 
devices, such as French drains or berms, that provide protection for the species, as described in the 
Stage 2 EIR/EIS. 



4-14 



Response. Reclamation accepts the recommendation. It will be implemented ttirough mitigation 
measures 7-13 and 7-18. 



Recommendation 7.2.15 

Avoid activities tiiat result in loss of oal< or shrubs that provide canopy cover to Diablo helianthella 
populations. 

Analysis. This recommendation is consistent with mitigation already proposed in the Recreation 
Use Suitability and Opportunities Report developed by CCWD and included in the project description in the 
Stage 2 EIR/EIS. 

Response. Reclamation accepts the recommendation. It will be implemented through mitigation 
measure 7-18. 



7.3 Special-Status Wildlife Recommendations 



Recommendation 7.3.1 

Revise the bald eagle study to include collection of mortality data on ferruginous hawks, tricolored 
blackbirds, mountain plovers, and other species. 

Analysis. Reclamation disagrees that the existing evidence shows conclusively that the Kellogg 
Creek watershed is a critical wintering area for ferruginous hawks and that the inundation of approximately 
750 acres of annual grassland and 750 acres of dryland-farmed areas will significantly affect this species or 
cause displacement of a significant number of birds. DFG's 1983 raptor study characterized raptors within 
a much larger study area surrounding the Los Vaqueros Project site. Thus, the Los Vaqueros site is 
prob»ably typical of a much larger surrounding area. Garrison (1990) found no evidence for a decline in this 
species in California, and his analysis indicated that the species is wkJespread in the state. 

DFG's peak population estimate of 20 birds for the estimated 60-square-mile region surrounding Los 
Vaqueros indicates that probably only one to two birds would be displaced by reservoir inundation. 
Because few birds would be displaced by the project, mortality due to turbine collisions would not likely 
increase. Mortality studies show that ferruginous hawks are killed less often relative to other raptors than 
expected based on their abundance (0.9% mortality versus 3.0% abundance) (Orloff et al. 1991). Finally, 
CCWD is acquiring approximately 13,000 acres of habitat surtatjie for foraging by wintering ferruginous 
hawks and will enhance this area for raptors by reducing grazing intensity and eliminating widespread 
ground squirrel poisoning. However, Reclamation and CCWD have agreed to implement this 
recommendation. 

Response. Reclamation modifies the recommendation to specify that CCWD should collect 
information on mortality of ferruginous hawks and other species incidental to studies of bald eagle mortality, 
but CCWD does not need to modify its proposed study design. 



Recommendation 7.3.2 

Conduct, with the cooperation of DFG and the Service, a pilot study to investigate the usefulness 
of grasslands of raptor perches of various designs to ferruginous hawks. 



4-15 



Analysis. See response to recommendation 7 3 1 above. Although Reclamation does not believe 
that the Los Vaqueros Project will result in any impacts on ferruginous hawks, Reclamation and CCWD are 
willing to participate in such a pilot study provided that the findings of the study are not considered to be 
binding. 

Response. Reclamation modifies this recommendation to state that CCWD will participate in a pilot 
study to be conducted by USFWS, DFG, or some other appropriate entity. CCWD participation will t>e 
limited to no more than $10,000. 



Recommendation 7.3.3 

Control cattle grazing to maintain ground squirrel populations to benefit hawks. 

Analysis. This recommendation has already been adopted by the CCWD and is being implemented 
on CCWD-owned lands. 

Response. Reclamation accepts the recommendation. It will be implemented through mitigation 
measure 8-4. 

Recommendation 7.3.4 

Maintain records of the amounts of CCWD diversions; provide these data as needed to agencies 
engaged in monitoring the status of the Bay-Delta Estuary (such as, for example, monitoring efforts 
established during implementation of the CVPIA or under the State's efforts to protect the Bay and Delta), 
including the Service. 

Analysis. CCWD has already proposed to maintain diversion records as part of its operations. 

Response. Reclamation accepts the recommendation. It will be implemented through mitigation 
measure 4-3. 

Recommendation 7.3.5 

Create, as an enhancement measure, a seasonal impoundment in one or more of the proposed 
reservoir's bays to sustain a cattail wetland during drawdowns to enhance tricolored blackbird habitat by 
maintaining a water barrier to mammalian predation. Creation of a shallow impoundment by construction 
of a low, gated, earthen or fill dike may provide an opportunity for significant enhancement at relatively low 
cost (both financially and in terms of water). This impoundment should be large enough to accommodate 
at least 50 pairs of tricolored blackbirds. 

Analysis. The conclusion that the Los Vaqueros Project would result in impacts on tricolored 
blackbird populatkans is not supported by the analysis in the FWCA report or extensive fieldwork conducted 
over a 6-year period by CCWD. Independent research conducted statewkje by Jones & Stokes Associates 
biologists (Beedy et al. 1991, Beedy and Hayworth 1993) also does not support the conclusion that road 
construction and subsequent traffic would cause impacts on tricolored blackbird colonies. 

The Stage 2 EIR/EIS indicates that no impacts are expected because no breeding habitat would 
be affected and only a small amount of wintering habitat (which is not limiting to the species) would be 
affected. 



4-16 



Creation of an impoundment as an enliancement measure would be expensive and would reduce 
reservoir storage. Also, it could enhance liabitat for tfie bullfrog and fish species that may cause detrimental 
impacts on special-status reptiles and amphibians. 

Response. Reclamation rejects the recommendation that CCWD should construct an in-reservoir 
Impoundment. Reclamation determines that the project will not cause a significant adverse impact on the 
tricolored blackbird. The recommendation is not reasonable or justifiable as an enhancement measure 
because its cost is not reasonable and the impoundment could lead to further impacts on special-status 
reptiles and amphibians. 



Recommendation 7.3.6 

Evaluate the benefits of converting, as an enhancement measure, a portion of the project area 
introduced annual grasslands to higher producing native grass species (e.g., blue wildrye and meadow 
barley) to improve the forage value for the tricolored blackbird. 

Analysis. See response to recommendation 7.3.5 above. Although Reclamation does not believe 
that the Los Vaqueros Project will result in any significant adverse impacts on the thcolored blackbird. 
Reclamation and CCWD are willing to conduct such an evaluation. 

Response. Reclamation modifies this recommendation to state that CCWD will conduct an 
evaluation of the benefits to the tricolored blackbird of converting a portion of the project area to native 
grasslands. This evaluation will consist only of literature review, expert opinion, and minor fieldwork, for a 
total amount not to exceed $10,000. 



Recommendation 7.3.7 

Include objectives for tricolored blackbirds in grassland management and monitoring. 

Analysis. Reclamation believes that the land management policies being implemented by CCWD 
on lands it currently owns will enhance the value of the watershed area for the tricolored blackbird. 
Reduced grazing will Increase seed and forage production for insects while maintaining the open character 
of the watershed lands, which is important for the tricolored blackbird. 

Response. Reclamation modifies this recommendation to state that CCWD will consider tricolored 
blackbird habitat requirements in its land management activities. 

Recommendation 7.3.8 

Provide, as an enhancement measure, reasonable measures to ensure nesting and cover habitat 
for the tricolored blackbird in wetlands and riparian areas, where such measures are compatible with the 
primary purposes of the mitigation projects. 

Analysis. See response to recommendation 7.3.5 above. Blackt>erries are used for nesting and 
may t>ecome established naturally at wetland mitigation sites or at certain areas on the edge of the reservoir. 

Response. Reclamation accepts this recommendation. It will be implemented through mitigation 
measure 7-6. 



4-17 



Recommendation 7.3.9 

Minimize erosion during the construction and relocation of Vasco Road. 

Analysis. CCWD as already adopted numerous measures to minimize erosion during construction. 

Response. Reclamation accepts this recommendation. It will be implemented through mitigation 
measure 7-9. 

Recommendation 7.3.10 

Estatdish policies to ensure that the project area's biological resources are protected from dogs. 
One option for providing such protection is to require that all dogs be leashed. 

Analysis. As part of its overall watershed management policy, CCWD will probably require that all 
pets be leashed on watershed lands. 

Response. Reclamation modifies the recommendation to specify that during its future recreation 
planning efforts, CCWD should consider effects of unleashed dogs and establish policies to ensure that 
important biological resources are protected. Leashing all dogs should be considered as one option to 
achieving protection. 

Recommendation 7.3.11 

Minimize pesticide use in all operations. Limit insect control measures under recreation plan to 
structures. 

Analysis and Response. Reclamation accepts this recommendation. The recommendation has 
already been adopted by CCWD and is being implemented on CCWD lands. It will continue to be 
implemented through mitigation measure 7-18. 

Recommendation 7.3.12 

Maintain livestock grazing at sufficient levels on remaining mountain plover foraging areas so as to 
maintain vegetation in open physiognomy disclimax. 

Analysis. Substantial areas that are suitable as plover foraging areas are being acquired by CCWD. 
CCWD intends to continue to graze lands at moderate intensity and continue existing dryland farming 
operations. 

Response. Reclamation accepts this recommendation. It will be implemented through mitigation 
measure 8-3. 



Recommendation 7.3.13 

On lands with a slope of less than 10%, disk and harrow soil within 5 to 10 days of any plowing which 
creates furrows during the period from September 1 through March 15. This will maintain suitable mountain 
plover foraging habitat. 



4-18 



Analysis. Dryland farming occurs on hills, not on flat ground within watershed lands. CCWD does 
not anticipate any need to modify ongoing agricultural practices given the potential high cost to lessees and 
minimal need and value for the plover. Continued agricultural use of lands will provide approximately the 
same habitat value for mountain plovers as has occurred in the past. 

Response. Reclamation rejects this recommendation as unjustifiable and unreasonable. 

Recommendation 7.3.14 

Participate in Bay-Delta wetlands restoration planning and efforts. 

Analysis. The Los Vaqueros Project does not have any impact on Bay-Delta wetlands. 

Response. Reclamation rejects this recommendation because it is unjustifiable. 

7.4 Special-Status Reptile and Amphibian Recommendations 



Recommendation 7.4.1 

Develop and implement a long-term monitoring program to examine the effectiveness of the 
proposed reptile and amphibian mitigation measures, both separately and in the context of a total program. 

Analysis. The special-status reptile and amphibian mitigation plan (currently in draft for agency 
review) has been prepared with advice from USFWS and DFG as a long-term mitigation and monitoring plan 
(Jones & Stokes Associates 1992a). Although some of the measures included in the plan have not been 
previously used for the particular species of concern, the plan has a reasonable probability of succeeding. 
Remedial measures will be implemented as needed. 

Response. Reclamation accepts this recommendation with the specification that monitoring will 
be conducted as specified in the special-status reptile and amphibian mitigation plan. 



Recommendation 7.4.2 

Develop success criteria tiased on target species' responses (rather than relying on habitat criteria) 
to evaluate the effectiveness of mitigation measures. 

Analysis. The intent of the Special-Status Reptile and Amphibian Mitigation Plan, as stated on 
page 4-4 of the plan, is to monitor species occurrence and habitat components over a 10-year period and 
to evaluate changes in species occurrence and population numbers in relation to habitat conditions (e.g., 
vegetation, hydrology, upland habitat quality, levels of human disturbance and predators). Thus, population 
and habitat monitoring will be used to determine whether changes in the amphibian and reptile community 
are related to changes in habitat quality. Remedial management measures will be implemented as needed. 

Response. Reclamation accepts this recommendation. It is consistent with commitments in the 
Stage 2 EIR/EIS and draft mitigation plan. 



4-19 



Recommendation 7.4.3 

Revise, with the assistance of DFG and the Service, ranking criteria for evaluating habitat quality for 
California red-Jegged frogs, California tiger salamanders, and western pond turtles. The proposed mitigation 
should also be revised, as appropriate, given any changes in ranking criteria for habitat quality. 

Analysis. Reclamation and CCWD believe that the habitat evaluations conducted by Jones & 
Stokes Associates (1992a) for the reptile and amphibian species were appropriate. CCWD intends to 
continue to work with USFWS and DFG to refine the criteria as necessary in preparing the final reptile and 
amphibian mitigation plan. 

Response. Reclamation modifies this recommendation to state that CCWD will continue to work 
with USFWS and DFG to identify appropriate bases for evaluating habitat and to develop appropriate 
mitigation. 



Recommendation 7.4.4 

Guarantee the continuation of proposed mitigation in perpetuity. Many of the mitigation measures 
are long-term proposals (such as the bullfrog control program). Without the commitment of Reclamation 
and CCWD, there is no guarantee that economic considerations would not lead to program termination. 

Analysis. All of CCWD's mitigation sites will be monitored as described in the draft mitigation plan. 
Remedial measures will be implemented as needed. Funding for mitigation and monitoring will be 
committed to during certification of the Stage 2 EIR/EIS and project approval. 

Response. Reclamation accepts this recommendation. It will be implemented through mitigation 
measures 7-6, 8-7, 8-8, and 8-10. 



Recommendation 7.4.5 

Develop, with DFG, the Service, and qualified research scientists, an alternative mitigation program, 
based on the acquisition and management of existing habitats, for implementation should the monitoring 
program reveal that the proposed mitigation is ineffective, because most of the proposals are experimental. 

Analysis. CCWD has already acquired a substantial amount of special -status reptile and amphibian 
habitat through its acquisition of the Kellogg Creek watershed. CCWD concurs that much can be learned 
from its mitigation proposals, and information gathered during monitoring will help guide any necessary 
remedial actions. CCWD does not view its reptile and amphibian mitigation proposal as a "technological 
fix", and many of the recommendations it has adopted were suggested by state and federal agency 
biologists. 

Response. Reclamation modifies this recommendation to specify that additional habitat acquisition 
is not warranted, but tfiat CCWD should continue its efforts with USFWS and DFG to refine the special-status 
reptile and amphibian plan so that mitigation takes the form of an adaptive management program to ensure 
that monitoring results are used to refine or modify mitigation actions over time. 



Recommendation 7.4.6 

Reexamine, in consultation with DFG and the Service, the desirability and likely effectiveness of the 
proposed relocation program for frogs and turtles. There is no evidence that animals so relocated will 
survive. 



4-20 



Analysis. Although the survival rate of relocated animals cannot be predicted, CCWD believes that 
it is preferable to attempt relocation rather than allow the animals to be inundated during reservoir filling. 
Relocation of animals to newly created habitat at mitigation areas or to existing ponds that have become 
depopulated due to recent drought seems particularly lil<ely to succeed. 

Response. Reclamation accepts this recommendation. It will be implemented through mitigation 
measures 8-9 and 8-1 1 . 



Recommendation 7.4.7 

Consult with DFG and the Service when planning future recreation facilities and implementation of 
the recreation development guidelines. 

Analysis. The recreation plan described in the Stage 2 EIR/EIS and other documents is conceptual. 
CCWD has adopted numerous feasible guidelines to ensure that impacts on special-status species do not 
occur. CCWD has agreed to continue to work with USFWS and DFG to refine the recreation plan as various 
features are proposed. 

Response. Reclamation accepts this recommendation. It will be implemented through mitigation 
measure 7-18. 



Recommendation 7.4.8 

Adopt as policy that Gambusia not be used for mosquito control in the Kellogg Creel< watershed 
or other lands associated with the project. Exceptions to this policy should be made only after consultation 
with the Service. 

Analysis. CCWD has incorporated design measures into wetland mitigation sites to reduce 
mosquito breeding habitat, including the ability to drawdown water levels rather than introduce mosquitofish 
for mosquito control. CCWD does not intend to encourage use of mosquitofish on watershed lands and 
does not anticipate major conflicts with day-use recreationists. CCWD will work with the local mosquito 
abatement district to minimize conflicts with aquatic reptile and amphibians. 

Response. Reclamation modifies the recommendation to specify that CCWD will minimize use of 
mosquitofish on its lands. 

Recommendation 7.4.9 

Revise the acreage of mitigation and compensation measures to reflect changes in estimates of the 
amount of occupied habitat. Surveys in 1993 revealed that earlier surveys underestimated the amount of 
habitat used by the California tiger salamander, California red-legged frog, and western pond turtle. 

Analysis. CCWD will reevaluate the amount of occupied habitat and adjust impact acreages to 
reflect minor changes in conclusions about species distribution that have resulted from 1993 surveys. These 
changes are minor because CCWD assumed in its evaluation that all suitable habitat was capable of 
supporting special-status amphibians and reptiles, even if the habitats were not found to be occupied during 
CCWD surveys. 

This conservative assumption was made because CCWD recognized that its surveys were being 
conducted during a series of dry years and tfiat under optimal conditions (e.g., the wetter conditions that 
occurred during DFG's [1983] surveys) additional areas would likely be occupied. CCWD included 



4-21 



consideration of patterns of occupancy by the species by assigning higher habitat values to areas that were 
more continuousiy occupied. 

Response. Reclamation modifies the recommendation to specify that CCWD will use the minor 
adjustments to impact acreages that resulted from surveys conducted during 1993 in its further mitigation 
planning. It will be implemented through mitigation measures 7-6 and 8-10. 

Recommendation 7.4.10 

Conduct an evaluation of the Del Valle Reservoir in Alameda County and its watershed to assess 
the status of the red-legged frog and identify factors allowing the species to persist in a situation that would 
appear to be unsuitable. DFG is aware that the species is present below the Del Valle Reservoir. This 
reservoir and its tributary and downstream habitats are analogous to the Kellogg Creek/Los Vaqueros 
Reservoir site. Although we believe the results of this study would not necessarily provide conclusive data, 
it may provide more information on the complicated interrelationships between reservoir projects and red- 
legged frog habitat. 

Analysis. Reclamation and CCWD agree that such information could be valuable to CCWD's 
mitigation efforts. 

Response. Reclamation modifies this recommendation to state that CCWD will evaluate the status 
of red-legged frogs in the Del Valle reservoir watershed area and identify factors that have allowed the 
species to persist despite apparently unsuitable conditions. CCWD's evaluation efforts will be limited to a 
cost not to exceed $15,000. 



7.5 Special Status Fish Recommendations 

Reclamation has received from USFWS a biological opinion regarding the effects of the Los 
Vaqueros Project on Delta smelt. The opinion indicates that the Los Vaqueros Project would not jeopardize 
the continued existence of the species and prescribes reasonable and prudent measures to minimize take 
of Delta smelt. The opinion also states that the reasonable and prudent measures are sufficient to protect 
longfin smelt and Sacramento splittail. 

Recommendation 7.5.1 

Subject reservoir fillings to the reasonable and prudent measures of the Service's biological opinion 
for delta smelt (1993). 

Analysis. Reclamation and CCWD fully intend to operate the Los Vaqueros Project in a manner 
consistent with the USFWS biological opinion for Delta smelt and the National Marine Fisheries Service 
(NMFS) opinion on winter-run Chinook salmon. 

Response. Reclamation accepts this recommendation. 

Recommendation 7.5.2 

Keep the timing of the 30-day no filling and no release period flexible. This period should be 
determined with concurrence from DFG, NMFS, and the Service. The Service. NMFS, and DFG should be 
provided with Reclamation's monthly forecasts to determine the 30-day period. 



4-22 



Analysis. This recommendation is similar to the requirements of the biological opinion for Delta 
smelt. 

Response. Reclamation modifies this recommendation to state that it will comply with term and 
condition (1)(b) of the biological opinion for Delta smelt. CCWD will submit to DFG, NMFS, and USFWS, 
per operation rule 6 as described in the biological assessment, by January 1 of each year a proposal for 
operating the Los Vaqueros Project. This group will notify CCWD and Reclamation, if necessary, to change 
the timing of the periods totaling 75 days when reservoir filling is to be avoided and the concurrent 30 days 
when all diversions are to be avoided. The periods shall consist of a 30-day period and a 45-day period with 
no reservoir filling that shall occur t»etween January 1 through July 31, and a concurrent period of 30 days 
with no diversions, to a maximum of 12,500 af. 



Recommendation 7.5.3 

Divert water, to the greatest extent possible, at the screened Old River intake, unless real-time 
monitoring indicates Rocl< Slough intake would not entrain Delta fish species of concern. This decision will 
be made by the Service, NMFS, and DFG, upon review of 1 full year of monitoring performed as described 
below. 



smelt. 



Analysis. This recommendation is similar to the requirements of the biological opinion for Delta 
Response. Reclamation accepts this recommendation. 



Recommendation 7.5.4 

Conduct real-time monitoring at all CCWD intakes 12 months/year for 3 years, commencing 
January 1 , 1994. A monitoring plan should be submitted to the Sen/ice for review within 30 days of issuance 
of the final FWCA report. 

Analysis. This recommendation is similar to the requirements of the biological opinion for Delta 
smelt. 

Response. Reclamation modifies this recommendation to state that Reclamation and CCWD will 
submit a monitoring plan for the Rock Slough intake within 90 days of issuance of the final FWCA report. 



Recommendation 7.5.5 • 

Include in this real-time monitoring plan the following: 

a. Sampling locations, sampling equipment, and frequency. The Service recommends 
sampling for a minimum of 4 consecutive days/week, 24 hours/day. 

b. All fish must be identified, counted, measured, and examined for biological data on growth, 
smoltification, and health. 

c. A commitment to return all live fish to the water, outskje the influence of the intakes. 

d. Make provisions to minimize fish mortalities to the greatest extent possible. All mortalities 
of federally listed species shall be reported to the appropriate agency in accordance with 
requirements identified in biological opinions for Delta smelt and winter-run chinook salmon. 



4-23 



Recording of mortalities should include sampling location, sampling gear, date and time, 
arxj fork length in millimeters. 

Analysis. This recommendation is similar to the requirements of the biological opinion for Delta 
smelt. 

Response. Reclamation modifies this response to state that CCWD and Reclamation will submit 
a comprehensive monitoring program to USFWS for its approval. The monitoring program may involve 
funding of the Interagency Ecological Study Program and will specify the timing and duration of monitoring 
efforts. 



Recommendation 7.5.6 

Provide the Rock Slough intake with an adequate fish screen, as required in PL 102-575. This 
screen must meet the criteria of the Service, DFG, and NMFS. As a non-federal agency, it would be 
appropriate for CCWD to participate in cost-share for this action. 

Analysis. CCWD has agreed to collaborate with Reclamation to ensure that screening the intake 
at Rock Slough in accordance with the CVPIA is completed by October 1998. Screening the Rock Slough 
intake was included as term and condition (2)a) in the biological opinion for Delta smelt. 

Response. Reclamation accepts this measure. 

Citations 



Beedy, E. C, and A. Hayworth. 1993. Tricolored blackbird {Agelaius tricolor) nesting failures in the Central 
Valley: general trends or isolated phenomenon? Pages 33-46 in Endangered and sensitive species of 
the San Joaquin Valley, California: their biology, management, and conservation. D. A. Williams, S. 
Byrne, and T. A. Rado (eds). California Energy Commission. Sacramento, CA. 

Beedy, EC, S. D. Sanders, and D. Bloom. 1991. Breeding status, distribution, and habitat associations of 
the tricolored blackbird {Agelaius tricolor) 1850-1989. U. S. Fish and Wildlife Service. Sacramento, CA. 

California Department of Fish and Game. 1983. Los Vaqueros Project - fish and wildlife impacts: a status 
report. Sacramento, CA. 

Contra Costa Water District and U.S. Bureau of Reclamation, Mid-Pacific Region. 1992. Stage 2 
environmental impact report/environmental impact statement for the Los Vaqueros Project, Contra 
Costa County, California. Draft. (JSA 90-211.) February. Concord and Sacramento, CA. 

Contra Costa Water District. 1992. Conceptual wetlands mitigation plan for the Los Vaqueros Project, 
February 18, 1992. Concord, CA. Technical assistance provided by Jones & Stokes Associates, Inc. 
(JSA 90-211.) Sacramento, CA. 

Garrison, B. A. 1990. Trends in wintering abundance and distribution of ferruginous hawks in California. 
Transactions of the western section of the wildlife society 25:51-56. 

Jones & Stokes Associates, Inc. 1989. Results of biological resource inventories and habitat evaluations 
in the Kellogg Creek watershed. (JSA 87-031.) Prepared for James M. Montgomery, Consulting 
Engineers, Walnut Creek, CA and Contra Costa Water District, Concord, CA. 



4-24 



. 1991a. A conceptual plan to mitigate impacts on valley oak habitat for the Los Vaqueros 

Reservoir Project. December. (JSA 90-211.) Sacramento, CA. Prepared for the Contra Costa Water 
District, Concord, CA. 

1991 b. Results of supplemental biological inventories conducted for the Los Vaqueros Project 



in and adjacent to Kellogg Creek watershed. (JSA 90-21 1 .) Sacramento, CA. Prepared for James M. 
Montgomery, Consulting Engineers, Walnut Creek, CA and Contra Costa Water District, Concord, CA. 

1991c. Recreation use suitability and opportunities report. Sacramento, CA. (JSA 90-239.) 



Prepared for Contra Costa Water District, Concord, CA. 
. 1992a. Draft special-status amphibian and reptile conceptual mitigation plan for the Los 



Vaqueros project. (JSA 92-078.) Sacramento, CA. Prepared for the Contra Costa Water District, 
Concord, CA. 

1992b. Alkali wetland mitigation pilot study: results of wetland investigations and 



enhancement. August. (JSA 90-309.) Sacramento, CA. Prepared for Contra Costa Water District, 
Concord, CA. 

1993a. Wetland mitigation plan for the Los Vaqueros project. Draft. January. (JSA 90-211.) 



Sacramento, CA. Prepared for Contra Costa Water District, Concord, CA. 

Orloff, S., A. Flannery, and G. Ahlborn. 1991. Wind turbine effects on avian activity, habitat use, and 
mortality progress report 1989-1990. BioSystems Analysis, Inc. Prepared for Alameda County Planning 
Department, Hayward, CA, and California Energy Commission, Sacramento, CA. 

U.S. Fish and Wildlife Service. 1993. Fish and Wildlife Coordination Act Report - Los Vaqueros Reservoir 
Project. Author's draft. Prepared for U.S. Bureau of Reclamation Mid-Pacific Region. Sacramento, CA. 



4-25 



Attachment 5. Letters of Comments Received on the Draft Stage 2 
EIR/EIS and Responses to Those Comments 



5-1 



5-2- 



TABLE OF CONTENTS 

Page 

Introduction 5-5 

List of Parties Providing Written Comments 5-5 

List of Parties Providing Oral Comments 5-6 

Responses to Comments of the U.S. Fish and Wildlife Service 5-16 

Responses to Comments of tiie U.S. Environmental Protection Agency 5-37 

Responses to Comments of the National Marine Fisheries Service 5-49 

Responses to Comments of the U.S. Army Corps of Engineers 5-58 

Responses to Comments of the California State Water Resources Control Board 5-57 

Responses to Comments of the California Department of Fish and Game - Region 3 5-84 

Responses to Comments of the California Department of Water Resources 5-89 

Responses to Comments of the Conta Costa County Public Works Department 5-93 

Responses to Comments of the East Bay Municipal Utility District 5-95 

Responses to Comments of the Delta Diablo Sanitation District 5-97 

Responses to Comments of the City of Livermore 5-100 

Responses to Comments of the Reclamation District No. 800 and Discovery Bay Reclamation 
and Drainage Maintenance District 5-104 

Responses to Comments of the San Ramon Valley Fire Protection District 5-106 

Responses to Comments of the Contra Costa County Board of Supervisors 5-111 

Responses to Comments of the State Route 4 Bypass Authority 5-116 

Responses to Comments of the East Bay Regional Park District 5-121 

Responses to Conrwnents of the Contra Costa Mosquito Abatement District 5-126 

Responses to Comments of the South DeJta Water Agency 5-130 

Responses to Comnr»ents of the Contra Costa County Rood Control and Water Conservation 
District 5-133 

Responses to Comnnents of the Contra Costa Sheriff-Coroner 5-135 

Responses to Comments of Joanne Dean-Freemire 5-138 



5-3- 



Responses to Comments of the GreenbeJt Alliance 5-141 

Responses to Comments of the James Hanson 5-144 

Responses to Comments of Delta Wetlands 5-147 

Responses to Comments of the Sierra Club - San Francisco Chapter 5-151 

Responses to Comments of Kenetech/U.S. Windpxjwer 5-156 

Responses to Comments of the Pacific Gas and Electric Company 5-160 

Responses to Conwnents of the East Bay Chapter of the California Native Plant Society 5-163 

Responses to Comments of the Contra Costa Cooncil 5-167 

Responses to Comments of the Cowell Ranch Project 5-176 

Responses to Comments of the League of Women Voters of the Bay Area 5-186 

Responses to Comments of Harold Bushaw 5-192 

Responses to Comments of the State Water Contractors 5-200 

Responses to Public Hearing Comments of David Mata 5-204 

Response to Public Hearing Comments of Tim Donohue 5-207 

Response to Public Hearing Comments of Tom Butterfield 5-209 

Response to Public Hearing Comments of Wesley Van Gilder 5-21 1 

Response to Public Hearing Comments of Wilhemena Andrade 5-213 

Response to Public Hearing Comments of Burt Weinstein 5-216 

Response to Public Hearing Comments of Frank Lehmkuhl 5-218 



5-4 



INTRODUCTION 



This attachfnent contains written and oral comments received on the draft Stage 2 EIR/EIS and 
CCWD's arxJ Reclamation's responses to those comments. Written comments are presented first, followed 
by oral comments. Each comment letter is numbered and individua) comnrwnts are numlDered within each 
letter. Vert>al comments by each individual are also numbered. Comnrtents and responses are presented 
side by side on each page, with comments appearing on the left side of the page and the corresponding 
responses aippearing on the right side of each page. Additions made to the body of the EIR/EIS in 
response to the comments are under1ir>ed to help Identify wtiere changes occurred. 

Several other documents are referenced in this attachment, lndudir>g the biological assessment for 
the Los Vaqueros Project, the detailed wetland mitigation plan, thte detailed valley oal< woodland mitigation 
plan, and Section 106 compliance nnaterials. These documents are included as appendices or attachments 
to this final EIR/EiS. The tMological assessment Is available from CCWD on request. 

UST OF PARTIES PROVIDING WRITTEN COMMENTS 



Federal and State Agencies 



Letter Number 



U.S. Fish and Wildlife Service 1 

U.S. Environmental Protection Agency 2 

National Marine Fisheries Service 3 

U.S. Army Corps of Engineers 4 

California State Water Resources Control Board 5 

Califomia Department of Fish and Game - Region 3 6 

Califomia Department of Water Resources 7 



Local Agencies 



Contra Costa County Public Works Department 8 

East Bay Municipal Utility District 9 

Delta Diablo Sanitation District 10 

City of Uvermore 1 1 
Reclamation District No. 800 and Discovery Bay Reclamation and Drainage 

Maintenarx:e District 12 

San RanxHi Valley Fire Protection District 13 

Contra Costa County Board of Supervisors 14 

State Route 4 Bypass Authority 15 

East Bay Regional Park District 16 

Contra Costa Mosquito At^atement District 17 



Letter Number 



South Delta Water Agency 18 

Contra Costa County Rood Control and Water Consen/ation District 19 

Contra Costa County Sheriff-Coroner 20 



5-5 



Irrteretted Groups, Corporations, and Individuals 



Joanne Dean-Freemire 21 

Greenbert AJIiance 22 

vianids A. Hanson 23 

Delta Wetlands 24 

Sierra Club - San Francisco Chapter 25 

Kenetech/U.S. Windpower 26 

Pacific Gas and Electric Company 27 

Caiifomia Native Plant Society - East Bay Chapter 28 

Contra Costa CouncI 29 

Cowe« Ranch Project 30 

l-eague o* Wonnen Voters o* the Bay Area 31 

Harold Bushaw 32 

State Water Contractors 33 



UST OF PARTIES PROVIDING ORAL COMMENTS 



David Mata PHI 

Tim Donohue - Sien^ Club PH2 

Tom Butterfield PH3 

WesJey Van Gilder PH4 

Wiihemena Arxjrade PH5 

Burt Weinstein - Bicycle Trails Council for the East Bay PH6 

Frank Lehmkuhl PH7 



5-6 




r : 



MftY 15 '92 07:89 US FISH & WILDLIFE LETTER NO. 1 

United States Department of the Interior 

FISH AND WILDLIFE SERVICE 

i^AJ v"i 2l '=\.^ 911 N£. 11th Avenue 

Portland, Oregon 97232-4181 

EC 92/0017 ^^Y I 4 1992 

Mr. John Gregg 

Program Manager 

Contra Costa Water District 

P.O. Box A121 

Concord, California 9^524 

Dear Mr. Gregg: 

?.„rvoir. a new '"Pi'l'"'""^"""""^ other Xcllitles. as naoe.sary. £«r 
conveyance P'P'"'-'' P^.i^tSgco^e^a S. provided £or Che uae and 

Engineers (Corps) . 

General Comments 

^e service understand, c.at ^-IJ-J;:-^,^^^^^^^^^^ "^ 

development of a 100,000 f J^-^^^^,""^^^",a " Old River #5. a 3 million 
watershed, a new water intake ^^^^J^^^ [^""^^^ gg.i^eh diameter pipeline from 
gallon transfer reservoir and l^^^^^J-^Tostl Canll! power transmission line, 
?he LOS Vaqueros Reservoir to the ^^f ^^^°^^^^^^^,;^ative as well as the 

;:eifoL:rilirr^ei- ^^^^^^ -— - ^^^ ''-' 

EIR/EIS. 

. ^ «n ^Hft Notice of Preparation (NOP) for the 
The service initially commented «" f ^^^«f J^^^/^J., ,S,,t.er comments on Public 
proposed EIR/EIS on May 2, 1990. "® *^J;^ . ^g ^990, The Service 
Notice 9000070. issued by the <^°7^^ /J.^^^^J^f ^^ ^1; 7. 1991. identifying 
provided a/P-i"^l»^ Ter^ice felt wo"d be potentially affected by the 
TrZlT'^^l S^ic?har^«di^ted with che^at.r District representatives 
regularly during the past 2 years. 

Because the Service believes that ^^^:^f//,Tali:ri-:r"p^o;rcr (C^I^^fn^ 
wetlands and the operations ^^/^^^^^f^^J^ef^nd indirect impacts to the 
State water ^-J-^ (^^^^ti^^fce ^e^n^^ed tgainst the Corps' issuance 
delta ecosystem (Delta), the Service recomm ^ (letter dated September 
of a Section 40A permit for the Los Vaj-ro« Project (1^^^ ^^^^^.^^ ^^^^ ^^^^^ 

18. 1992). we have also repeatedly ^^**^^f *^^^^^ii Usced San Joaquin kit 

would likely be ^^^if^^-^f P;:ries tn:iudtng\hi proposed-for-listing 
fox and on various Delta fish species e. ^..,,,-n 

delta smelt {Hypomesus transpaciJicus) . RECElVtU 

5-7 MAY 1 5 1992 



MfHY 15 '92 07:10 US FISH g WILDLIFE 



P. 3 



Mr. John Gregg 

The project would require . section 404 permit from the Corps ^^^ ^^^^^^^^ing 
fill into jurisdictional wetlands and navigable "Waters of the United States . 
The development of the proposed project would inipact ^PP^^'^J'^f ^J^^^^ J"^^, , 
classified as "Waters of the United States". They include 1.3 acres of alkali 
meadows, 11.6 acres of alkali marshes. 0.001 acre of northern claypan vernal 
pool 3.3 acres of willow- cottonwood riparian woodlands, and 1.9 acres or 
drainages. To offset the loss of wetlands acreage and values a conceptual _ 
mitigation plan has been developed. While this plan has not been included in 
the draft EIR/EIS. the Service recommends that the mitigation and monitoring 
plan and legal commitments to them be included by appendix in the final 
EIR/EIS. 

The proposed project would have significant effects on federally listed, 
endangered, threatened, proposed, and candidate plant and antiaal species. They 
include but are not limited to the San Joaquin kit fox (Vulpes macrocis 
mucicn) , American peregrine falcon (Faico peregrinus aixatum) . bald eagle 
(Haliaeecus leucocephalus) . loggerhead shrike {Lanius ludovLcianus) . longhorn 
fairy shrimp {Branchinecta longiancenns) , vernal pool fairy shrimp 
lBranchiTi6cta lynch i) , ^est«.m spadefoot toad (.Scephiopus hamaondi) , 
California red-legged frog (Rana aurora drajtoni) . California tiger salamander 
iAmbjstoma eiginum califomianse) , western pond turtle (Clemmys marmoraca) , 
winter-run chinook salmon {Oncorhynchus tshavycscha) , and delta smelt 
(Hypomesus cranspacificus) . 

The Service generally agrees that this project would meet the primary 
objective of improving water quality. However, the Service finds that this 
project would not meet many secondary objectives, which include maintaining 
and enhancing fish and wildlife resources, providing an environmentally 
acceptable project, and providing for fisheries benefits in the Delta. 

Results of the Los Vaqueros biological inventories and other studies in 
eastern Contra Costa County indicate that the entire project site is within 
the range of the endangered San Joaquin kit fox. The permanent and temporary 
losses of habitat for the San Joaquin kit fox resulting from this project have 
not been adequately quantified because; 1) only areas which are within 2 
miles of kit fox sign are considered occupied habitat; 2) some habitats which 
are considered unsuitable are used by kit foxes; and 3) impacts associated 
with the Los Vaquaros Pipeline and Recreational facilities are not quantified. 
The Service recommends that complete quantification of kit fox habitat 
permanently and temporarily affected by the project and corrections of the 
identified omissions would be provided In the final EIR/EIS. 

The potential for the project to fragment kit fox habitat needs to be 
addressed. Round Valley and adjacent lands that support kit foxes may be 
isolated from the remainder o£ the kit fox population by the Implementation of 
this project. Measures to avoid, minimize, and compensate for this effect 
should be identified. 

The draft EIR/EIS assumes that the Los Vaqueros project is a relatively minor 
project, when compared to the existing operations of the CVP and SWP and that 
It does not contribute significantly to the cumulative effects that water 



i 
i 



1-4 



1--1 



1-6 



5-& 



MAY 15 '92 07:11 US FISH & WILDLIFE P. 4 

3 
Mr. John Gr^gg 

Sren«:c:rrr:%?;in=an"""rS ..rr.n. .«enc oi vat« v,Uh..a-.l» 
and exports. 

The service finds ch.. the analysis of ^^e n^/J/^^^f.^^/rot^::' ^frtJed 
delta fish specie, which n.ay ^e^pacted by the P'^J-^ ^^,^^^, „,^1, „^i,h 
from quantitative estimates "data but rather ^^ ^^^.^^ ^^^^^^^^ 
may or may not be accurate. The "^^*^. ^t""?^.?!- facilities. The actual 
StLline Lta of fish -"^^--^.J^/ .rt".htu!d're'i::d co estimate the 
entrainment data from '^[^^/"fy .'?7^"Jgcted at the Old River #5 location, 
amount of entrainment that could ^e expected at addressed impact. 

The service finds that ^^^/"fj^JJ^f'^^^ recommends that baseline data 
ZT. rrat:d";:re:ts:Urt« :;uveries and net upon contracted amount. 

The water District has applied for «-- f £:://,rarvrrIo:s'tofattLf 'aAd'^ 
acre-feet per year of water which "^uld be diverted at ^«i° 350 

pumped at a rate of 250 cubic feet per second <if^J ^^ ^ be diverted, nor 
J^at RocVc Slough, ^^^t^en^a^re^: d^THhelrrf t ElVEIS . The final 
these pumping rates have been »«^f **"^J,J.^^%°^^s of water, and explain the 
ElR/ElS should provide the amount ^^ /^P^^f^^^^^tn the drait ElR/EIS 
difference between the amount of water ^^^f ^^"^^^ Jllli^A for by the Water 
(195.000 -re-feet per year) and the -o-f^'f ^te^: jpp^ied to^J^^ ^^^ 

District. In the final EIR/EIS. the "^^^^ °^*" "louKh the proposed Old 

amounts . 
Specific Comments 

contract that the Water District has ^^f ^^^^^^"^- ^^^tr demands would be 
estimate, that, through conservation and reclamation water deman 

approximately 188.000 acre-feet P« year^ „!!;" the I^s Vaqueros reservoir, 
inclusive of the water needed J^ fill *«* operate the Los Vaqu ^^^ ^^^^^^^ 

or would additional -unappropriated water ^* "''^^^^•J.26? Without a clear 
water levels as stated on pages 1-12 2-5^ 3-^^^ ^^^^ ^^^ ^^^^^^ -^ 

statement on how much water the Water P'-^^J^'^^^Juxo project on Delta 
is impossible to quantitatively determine the effects of the proj 
fish species. 

,,,^: The draft HIV^IS uses^he DWRSIK operat, s model J-loped^by^the 
DWR to Simulate flows and water budgets, ^his mocei / ^^^^ ^^^ 
demands occurring between 1922 and l"8'""*f*i,^^ts occurring in the 
demand data through 1990. Due to jt^%P0^f^!^"^/„^f J^^e tts analysis of Delta 
Delta, the Service requests that the ^^^1 "^/"^^H* [H^^ 19^0. 
impacts on actual flow and water demand data through at least 



5-9^ 



MftY 15 '92 07:11 US FISH g WILDLIFE 



1-14 



^- '° '' ,ncr...e m reverse flows within 

Paee 3^ The DWRSIM model suggests ^^^^ t;;/^^ ^ ^^3ult of the project, 
c hflower San Joaquin River is likely to occur as a r ^^^^^ _ ^^^^^^^ ^^^ ^ 
5^e fi^l nVElS needs to quantify the number of re ^^^^^ ^^^^ ^^^"^^^Lp 
latest flow associated with these ^:'^^" ' ^*' f i^ries resources and to SWP 
LTa^d^Lt'a. through at ^"-2^^,^„,?,::r.h:ulihr addressed in the final 
and CVP project operations from these tiows 

^^^^^j^^lU^J^: Entrainn>ent of f ^.^f/.^s^^^Sithouraccu^rat: Hfi- ^"' M2l 

^^^Sl^^'^t^ovided in the ^^J^i^^J^^f.^'.^.e of t^^e Water District's current 

It i« impossible to determina the aignincan 

or future project impacts. ^^ 

p,,. z>.24: The document states that l^^ll^f^^lZ^'Z by tSrsw^'anf^P /tt^e 
^fi^Ti; District is amall J^"^/",tsheries is Ussthan^lgnif leant. Without 
water District's impacts on Delta f"^"J" "^attment cannot be substantiated, 
quantitative data on fish e"^"'"°!^'' ^eitalc^Utive effect on the total 
?^ proposed action would have an ^^"^^'ff ^/^^^ smelt become federally 
Ske^f delta smelt by -f " P"^*^" " ^'/c T^l U>. Vaqueros project "may 
listed, the service would likely HffH District should identify and 

final EIR/EIS. 

,,,,^. The .nvi^onmental document conclu^^^^^^ - -^ 

bCing siinificantly *«^^^^^^^*""'f §/oposed rule was published in the 
substantiation. On October 3. 1991. a P"P^^ ^ ^ threatened species 
S^^^^^mst^ (36 nt 50075) to^Ust the delta smelt^ Endangered Species Act 
subject to protection under the mandates ^^J-"" Sacramento - San Joaquin 

:fl973. as'amended (Act) ^// 'tn'the' early 197S's has experienced a 10- 
Delta's most abundant native fish in ^^« "^Va/bee; attributed to extended 
fold decline since that time^ ^"^^ns of freshwater inflow to the Delta, 
drought period., coupled with ^-^^^'.^llll f^^J^^ Variations in population 
.nd Lte?.d timing and/or ^vr-.on of w-t*r «^^^"^- ^^^^ ,, ,, j^,,,.ts 1 
levels are not unusual in ^J^^J^*''^"^^^^^ ^e delta smelt has shown no 
subject to cyclic P"'=^^J*^'°"*\o velrs The effects of the current drought 
apparent recovery over <=^«/*", ^° y**". Zzlv exports, likely would extend 
on the delta smelt. <=-P^/J,f,^^ °"bf;onl^en though precipitation rates 
into future wet years and P^^^^^^^^^^^^^ed to be filUd. Therefore, outflov 
aay Increase, upstream ""^^^^f "^'ji^.^tlt would not likely substantially 
conditions needed to recover ^^^^!i"/Xut project conditions. U pumpinS 
iroprove in the i™!'-^-^^"^/^;^^^^,: ^f/easl ovir cur'rent baseline during wet 
with the project ^^ ^^^^^^^^.^^^^ed in the final EIR/EIS why reductions m 
years, rationale should ^f P^°^^ ^ pumping, would not result in 
outflow, resulting ^"'"^^^^^'^f ""^t K it. continued existence is. in 
significant impacts to the delta -^^^^ jhen x ^^^^^^^ ^^^^^ 

part, hinged to improved habitat conaition> 

5-ro 



1-15 






MPlY 15 '92 07:12 US FISH & WILDLIFE P. 6 



Mr. John Gregg 



Civen the delta s.«U's failure ^ -"^ ^.^f/.^c ^dH Zlt^' e^^^V^^^ " 
conditions, the --^'^^""^^^^^^^rerSithdrlwals for Contra Co.ta County 
support it, «««<^i^»^°" 5^^ "foSta exports are not significantly affecting 
operating, together with °<=^"^^^i^* ^^^°"^' ^^pport this conclusion, given 
thi. species. ^^^ *^];^'^*=%",f"^^de!tasmel? population? Why are the 
the continuing downward trends in the ^^J" J^^'^^^^Ji^e data is not 
impacts i----^^,j:,,^J,^^r,rdriory "--"'the i^acts? The final 

sufficient *-<*/°^,^^f ^^ita ?^ ^ project changes to a timing of water 
EIR/EIS also needs to explain wny P^«J crucial to delta smelt 
wuU.w.l durln. ^. P" »^^:J- t:1i::/:i:M««l wouX. not r..uU In . 
reproduction, and why an increase in wov. 
significant impact to the delta saelt. 

,,,,^: XK. -lr»»en«l .oc^.n. -«»»- ;P«J^H...l^.^-;-i^:» 

,uaUty n«dea - -j-'j^J^^ SrSpt"" «f Tcrsluof .e.sur.s ^t b. 
ot:h.r n.tiv. Delta «»*^«'", th.ir impU».ntatlon «ould athl.v. full 
fully .««.«se<J to ensut. that *"' i'^, '"°" ... „„ i„,ct tor another, 
proteotion of *%f "%'"'^5s':trn.^edrto *^,rteir..>.l».. how proposed 

different life stages. 

^-5^^ rsar/.rtn^^tVarr;iorrinr^iirsrtt:n%«i.ita f.ah ■ 

production, the Water uisuricc »*» "v ^ fan .run salmon, steelhead, and 

T^^^d-ha!^^':hr^:-rart^rg :Lrt ^ur^re^ ;rov?Sst benefit to winter- 

^r^nTaLor:; :^herf i^^ ^^ecf es . ^^^--^^^^J-J-.Torid^re^ct Oelta 
mitigation measures that would ensure that '•^ PJ°J"^ sienificant 
fish species or conclude that the project would have a significant 
uiffliitigatable impact on Delta fisheries. 

7 11 7 4V AS stated in the draft EIR/EIS. attempts to establish new. " 
£flg^B 7-11 7-4 1- ^*^;"*^^f special status plants in the wild, generally 
self-sustaining populations of special ^"'^^ J^ -ctemoted for most of the 
have not been successful, or ^-^. ^5^7?" u^ros Pro^^ct Although mitigation 
species that may be impacted by ^^* ^^^tJ^^^J-.^i^ loss of special status 
A be c.rri.d out. th. ^--"/^J^^irs^.^.t^^^itrgrted to iLs th'an significant 
plant populations ^o^^^ ^^%^^ ^aeesS- 11 through S-IS. Thus, we recommend 
levels, as stated i^7*^^*^;^:f^^%learly state in the final EIR/EIS that 

communities may be likely. 

7 17 7 38- Mitigation objectives should specifically Include a factor 
F^f^ft 7-37, 7-36. Mitigation « J . gcandpoint of how long a 

::ff-r::tlr""iif "riurr'^i^-"'- - »'" Sknet for haseune 



1-16 



1-17 



1-18 



1-19 



5-1 '1 



MAY 15 '92 07:13 US FISH & WILDLIFE 



Mr. John Gregg 

conditions. Application of che surface water ^-tor -;;^^J TZllotnt'^V.', 
as defined, and should be redefined from a more ^^^"^"^^^f ^xa^le) ' to a 
ability of a specific kind of habitat f""^^tLr^^^^J,,idLt^dlife 
pond for a sufficient duration to provxda habitat for resio 
(including invertebrate) species. 

Pag e 7-3B : Success criteria »^o;i^.5tca?ir.p:c!:s'::i^Lt?t:i'i:d ^i^lirtltj! 
to high quality habitat sites specifically ^P"J" "^^^^^^ ^^^er. Total 
particularly native species, in addition to ""^.^^^^^^^^^f 3,^cess of 
vegetative cover is inadequate by itself as a valid measure 
either habitat creation, restoration, or enhancement. 

Monitoring of mitigation sites should be for a -^"^X^^.t^r.^n'^rth^r' 

methods being employed are highly experimental. 

T.K1.. ft.;, and 8-3 : These tables list the numerous candidate «P*<^i«^^'^ 

In addition under the terms of a settlement agreement for a lawsuit b""^gf^^ 
l; :' entuonmental group, the Service will ^^^^"^f^SProPOsed rule n the 
near future to list a number of category-1 candidate plant species, inciuamg 
some or all of those in the project area. 

The loggerhead shrike and the western spadefoot toad are two candidate species 
I^cordff from this region of California, but were not J"/-"J ^/^^.f^ts 
EIR/EIS Ue recommend that adequate surveys be conducted for these animals 
and the 'service be contacted if either are found to be present in the proposed 
project ar^ Details on the impacts and mitigations for the adverse impacts 
should be provided to the Service. 

The draft EIR/EIS does not contain details on the effects of the proposed 
project on the candidate Alameda striped whipsnake (Masricophis lacer^lis 
Lrixaijchus) The Service recommends that the Issues regarding adverse 
tm^I^'tld mitigations for this species be fully resolved to the satisfaction 
of Che Service in the final environmental documents. J 

.„-. . 0.-.A ft.i7 8.20. 8-2 ^ S-^2, 8.32. 8-34: Only areas within 2 miles of 
a kit fox scat or sighting w«e considered kit fox habitat for the assessment 
of permanent and temporary losses of habitat We did not "^J^^"^,^" ^^^ 
analysis technique, contrary to statements made In the draft EIR/EIS. and may 
have resulted in exclusion of suitable kit fox habitat from consideration. 
SiRhtines and sign of kit foxes were found in the inundation zone, and east 
and west of the proposed reservoir. Suitable habitat is continuous In this 
region and kit foxes likely occupy different areas at different times. 
Therefore, the entire area should be considered kit fox habitat, where habitat 
requisites for kit fox exist. 



5-12 



MPIY 15 '92 07:14 US FISH & WILDLIFE P. 8 



Mr. John Gregg 

V, K-!(-«rc «r6 assessed unsuitable for kit fox. yet 

«._„.!. fl 1 /; fl-90 8-23- Some habitats are asbcaaov* ""= ^^„„ 

Page 8-lf) ti'.i'J, ° '^^^ - . * - ^i e. wetlands and some 

they have been shown to be occupied by kit f^*^** ^^'^^ , woodlands with low 
agricultural lands). Grasslands. -^^-"f\^*f/^J:;iraU be colder ed kit 

c^nsities of trees, -^^•^»* 'S'"^"^^;"^,^*"^' jfices Jor kit fox are 
fox habitat in this region, because habitat requisites ror 

provided on sice. 

P..e 8 18 P... 8-20 - Construction of the 12.»ile-long lx)S Vaqueros Pipeline 
pAf>e 8' in rage o ^v.- -^^ v-«./.v«ari on facilities would likely 

and construction and operation of the ""^^^"^^/^^^i^^^ These habitat 

v-\i SLrr/^::S.Knr:.itn.-":.-"t»vM.a .». ...» 

effects . 

„ «/s ^u »v « 99 • The realignment of Vasco Road would significantly 
ppf,^ 8.?0 through 8-2Z. The '^e^^^snmen^ ^ ^ traffic in an 

affect kit foxes, because the road ^^^^^^^J^^^f ^^^^^^ associated with this 

habitat fragmentation and i^^^^^^^^f ^f°^ in a aJel previously without 
pUce»ent of the new. 1^"^^!^ «*^«^^f ,^^i,i\i .%"* f orlging and denning for 
?oads. and a reduction i-^^f^^ey-^^^L LSletranai;fis'of these effects 
some distance from the new roadway, a mot*. / , . -^0^' ^ is pursued, we 

i:rr1.srA*\i PurcMsId « c,.^ns.te f« h.Mc« 10.... du. t. the 
relocation of Vasco Road. 

fl 10 8 90- Raptors are commonly killed by wind turbines in the project 

pirttcip'tt ircontinuing studies to find methods of avoiding raptor 
mortalities caused by wind turbines. 

\ir.,uHzi'T'^t i:".ri^"5:f tx.irr."-ui ;;i.uti... .. ... 

Migratory Bird Treaty Act. 

5-13 



MftY 



15 '92 07:14 US FISH S WILDLIFE 



P. 9 



Mr. John Gregg ^^^ton urban development. 

-^ bv aericuUural ^«"^^^^^*'": „, been petitioned 

construction of ."If icl»lt> __^ ^^^ ^ 1„ tflel^tt bulUroj" and 

.<^,u.t. .tt.8. -"; i\^\Zii b. o^-i^Xu.r^tiirr.i^.^a..... i.."us 

mitigated. Specint. v y^^.^^ that are habitat tot <- reduction or 

exotic fishes from ^^'^".^^f^he impact and mitigation ^^J^^^^^^^nders. 
.hould be P^'>^^<i*^^^S*'/';Lse burrows are utilized ^Y ^^^^//^ ^e 
loss of ground ^^^^"^^'^/be provided regarding impacts "^^J^°^ „« 
Further information ^^^^^^^^^ta "ler salamander movemenr ^^f ^f "^^^^n that 
^proposed proJec..oa^if-^^ . 

recommend that tne ii.tux^ manage California ciger 

„ai be utilized to ,>rot.tt ^^^^^ ^^ ^^^^^^^y - 

Infected by ^'•- t"^'ro:."t;r=.iid.t/.nL.l. .. -mit^/Iflrefs^ni^U 
petitioned to "" ^f "«r„e ourr.ntly "^''"'"V^' "e T^. Service 

„co™ond ^^»:J^to":nd11ufor„U r.d-lees.d froj be resolved in 

western pond turtie auu 

envlron..nt.l documents. looghom f»lry 

^. caiforni. linderleiis. vernel .ooi f^iry ^^-^^.-ttfttoLdJo Ust 

future. Although the <l^-^^/iy^'^^ed by direct or indirect (I.e. dust. 

S^:«ri:^titrrr^.-3^^^ 

service "CO-end. th.t the Issues^r |.^^^ |„„„^ent.l docu^nt.. 

for these species be resoj-vc 

impacts to red-legged f"g' ^f/^^°:^i*3rrabitai*^anc;ment Tas^ot been 

as endangered, chereroie. 

5-14 



l-2t 




1-311 



MAY 15 '9d 07:15 US FISH & WILDLIFE 



P. 10 



Mr. John Gregg 9 

significant issue. We recommend pilot studies to establish effectiveness of 
mitigation measures proposed. 

Page B-285 (Technical Report 1 : The use of the Kjelson model, which was 
developed for fall -run salmon and used to evaluate the effect of alternative 
operations on salmon mortality during April, May, and June, may not be valid 
for other salmon runs and time periods. The Water District needs to provide 
data proving that the model is valid for time periods outside of the original 
model's assumptions. 

Pa p ;e B-287 (Technical Report) : The entrainment data for the draft EIR/EIS has 
been based on data collected between 1981 and 1988; analysis should include 
data collected through Che spring of 1992. Substantial data from the spring 
1992 winter -r\in indicates that entrainment losses from salmon originating in 
the Sacramento river may be much higher than previously believed. 



1-32 



1-33 



Summary Comments 

The Service recommends that a revised or supplemental draft EIR/EIS be 
prepared which includes the final mitigation plan, revised quantitative 
fisheries data, and complete disclosure of all water rights activities and 
proposed operations, including the use of "unappropriated" or "surplus" water. 
The project's preferred alternative would have significant adverse impacts on 
wildlife and fisheries, the proposed mitigation would not compensate for the 
loss of fish, wildlife, or habitat values, and will contribute to significant 
cumulative impacts to winter- run salmon and delta smelt. The environmental 
document contains inadequate information to support its conclusion that the 
continued existence of the delta smelt is not jeopardized under current or 
future operations without or with the proposed action. 

Because the proposed project would have significant adverse impacts on 
wildlife and habitat values, we continue to recommend against permit issuance 
and certification of the draft EIR/EIS. Should this project be pursued, we 
also recommend that the Bureau Initiate formal consultation on the etwiangered 
San Joaquin kit fox and formal conferencing on the delta smelt, proposed for 
listing as a threatened species. We recommend that formal conferencing on the 
delta smelt be delayed until environmental baseline conditions ere established 
as part of the on-going consultation on the CVP operating criteria and 
planning. 

We have appreciated the opportunity to comment. 

Sincerely, 



1-34 



1-35 




WILLIAM E. MAF^qN 
Acting Regional Director 



5-T5 



Response to Comments of the U.S. Fish and Wildlife Service 



1-1. The wetland mitigation pian is incorporated as a separately bound appendix to the final Stage 2 

EIR/EIS. A plan to compJy with the mitigation monitoring and reporting requirements of CEQA 
wiJI also be adopted by CCWD as required by state law. Legal commitments to mitigation can be 
made only as part of approving the proposed action. Such legal commitments will be made In 
the findings of fact adopted by CCWD in compliance with CEQA and the record of decision 
approved by Reclamation. CCWD and Reclamation also anticipate that various permits required 
to proceed with the project, such as the Section 404 permit, will contain conditions requiring 
implementation of the proposed mitigation measures. 

1-2. USFWS has issued a biological opinion finding that the project would not jeopardize the continued 

existence of the San Joaquin kit fox or bald eagle, and has prescribed reasonable and prudent 
nneasures to minimize take of these species. The An>erican peregrine falcon and western 
spadefoot toad do not occur in the project area. Loggertiead shrike are very common in the 
project area and the Los Vaqueros Project would have only minor effects on habitat for this 
species. The longhorn fairy shrimp and vernal pool fairy shrimp are rare and do occur in the 
project area, but the Los Vaqueros Project would have no impacts on these species and would 
result in substantial habitat protection. 

Because of CCWD's mitigation commitnr>ents, impacts on the remaining species are also less than 
significant as described in the Stage 2 EIR/EIS and the biological assessment submitted to 
USFWS. 

1-3. CCWD recognizes that the proposed action would have significant impacts on some fish and 

wildlife resources and has therefore proposed water facility operations and mitigation measures 
to reduce these impacts to less-than-significant levels wherever practicable. CCWD also believes 
that the proposed action, which includes the protection and improved management of nearly 
20,000 acres of contiguous habitat area, will benefit wildlife resources. 

The proposed action will increase CCWD's operational flexibility, and CCWD arxj Reclamation have 
worked closely with USFWS, DFG, and NMFS to develop project operations that minimize impacts 
on Delta fisheries and provide net environmental benefits. 

1-4. The biological assessment for terrestrial species, sent to USFWS June 1, 1992, along with 

additional information developed during formal consultation, quantifies kit fox habitat permanently 
and temporarily affected by the project for all project components, including recreational facilities 
and the Los Vaqueros pipeline (referred to as the water pipeline). After several discussions with 
USFWS and DFG after publication of the draft Stage 2 EIR/EIS and before preparation of the 
biologk^al assessment, it was agreed that the entire project site is within the range of the San 
Joaquin kit fox and all suitable habitat is considered occupied. Suitable habitat was agreed to 
include ail grasslands, valley oak savanna, and dryland farmed lands. 

1-5. Comment noted. CCWD and Redamatk>n have analyzed the potential effects of habitat 

fragnnentation on kit fox tfiat could result from project facilities, including the Los Vaqueros 
Reservoir and relocated Vasco Road. This analysis, with mitigation and compensation measures, 
was included in the bkilogical assessment that was sent by Reclamation to USFWS. CCWD has 
also identified recreation facilities that have been eliminated to reduce impacts and further 
minimize the potential for fragmentation, as described in USFWS's biological opinion. 



Rosponae to Comments of the U.S. Fish and Wildlife Service 



5-16 



d 

^ 



1-6. The draft Stage 2 EIR/EIS does, in fact, identify numerous impacts on Delta fisfieries as 

contributing in a minor way to significant cumulative impacts (see pages 4-25 and 4-26 for 
examples). CCWD and Reclamation recognize and state in Cfiapter 4 of the Stage 2 EIR/EIS, 
"Delta System Fisheries" that, while project-related diversions are small compared to total Delta 
diversions, CCWD's incremental additions to the cumulative impact of all Delta diversions are 
significant. The Los Vaqueros Project itself, however, will not result in increases in Delta 
diversions, except for initial filling of the reservoir and a small amount to offset evaporation from 
the reservoir. 

1-7. The effects of alternative operations were evaluated relative to existing conditions, which includes 

existing levels of water deliveries to CCWD. The analysis also evaluated the effects of alternative 
operations under future demand corxJitions. Future operations (for all alternatives including the 
No-Action Alternative) were tfien compared to the existing (baseline) condition. 

Baseline fish entrainment data are not availat)le for the existing CCWD intake on Rock Slough. 
Data on fish entrained in the Contra Costa Canal fiave been collected sporadically, but the data 
fiave not been collected in a manner tfiat allows estinnation of entrainment rates. CCWD will be 
monitoring fish entrainment at its intakes for the Los Vaqueros Project. 

The use of historic salvage data for the CVP pumps (Tracy) to estimate the amount of entrainment 
tfiat couW be expected at the Old River No. 5 location is questionable. The CVP pumps appear 
to export proportionally more San Joaquin River water than the SWP pumps. The SWP pumps 
export proportionally more Sacramento River water, which travels via Old and MkJdIe Rivers. 
Entrainment at the SWP pumps (into Oifton Court Forebay) is more representative than 
entrainment at the CVP pumps for estimating entrainment that would occur at an Old River or 
Rock Slough intake. Where feasible, historic SWP salvage data were used to calibrate tfie 
entrainment models. 

Entrainment at the SWP and CVP intakes is a small part of the total mortality attributable to water 
project operations in the Delta. Using historic salvage data to estimate impacts ignores changes 
to Delta flow patterns and other physk;al conditions and focuses on the volume of export. Historic 
entrainment (salvage) data provide a reasonable estimate of temporal distribution, but many other 
factors must t>e considered when evaluating numt)ers of fish lost per volume pumped. These 
factors Include annual variation in fish numbers, fish behavior and life history, and Delta water 
transport patterns. 

The impact assessment models used in the draft Stage 2 EIR/EIS were developed to evaluate the 
effects of changes in transport pattems and the effects of increased diversion. The historic 
salvage provided a base for estimating temporal distribution and a k>ase level of entrainment urxJer 
known conditions. The models provide not only an estimate of entrainment loss, but also an 
estimate of changes in entrainnrtent under variable Delta transport conditions, including closure of 
tfie Delta Cross Channel gates, reverse flow in the lower San Joaquin River, and variat^le inflow 
sources. The models also allow consideration of salinity and the associated distribution of some 
species. 

The models fxovide valuable information when used to compare alternative operations. The 
models incorporate available informatton on species life history, effects of Delta transport pattems. 
and historic entrainment. Use of entrainment data alone would also not be accurate in a predictive 
sense and would not incorporate available information. The best available tools were used to 
evEduate the impacts of the eiltemative operations. Additionally, the biological opinion for Delta 
smelt bases its analysis in part on the Impact analysis from the impact assessment models. 



Response lo Comments of the U.S. Fish and WildlUe Service 

5-17 



1-8. CCWD has two water right applications pending before the Califomia State Water Resources 

Contrd Board for the Los Vaqueros Project. Application 20245 Is for diversion into storage of up 
to 163,000 af/yr at the Los Vaqueros Reservoir site or, alternatively, up to 135,000 af/yr at the 
Kellogg Reservoir site. Application 25516 is a partial assignment of a state filing for diversion from 
Kellogg Creek. Application 25516 Includes a storage component of 10,800 af/yr at the Los 
Vaqueros Reservoir site, and 14,800 af/yr at the Kellogg Reservoir site. In addition, application 
25516 Indudes a small direct dh/ersion component from Kellogg Creek. 

Arthough CCWD had determined which altematives would be addressed in its EIR/EIS for the Los 
Vaqueros Project, CCWD filed these water right applicatkxis with the California State Water 
Resources Control Board before completing Its extensive ahematives analysis and the draft 
Stage 2 EIR/EIS. The water right application process provides the ability to reduce the quantities 
and rates of water diversion, but does not allow an application to be increased without refiling the 
application. 

To ensure that feasible alternatives were not eliminated and to minimize potential schedule delays 
caused by the need to refile an applkatkxi if changes in the project occurred, CCWD intentionally 
filed applications for larger quantities of water and greater rates of diversion tfian its projected 
need. The Stage 2 EIR/EIS, however, only analyzes, and provides environmental documentation 
for, altematives consistent with CCWD's identified water quality and reliability objectives. 

The water rights applications will be reduced to be consistent with the CCWD staff-preferred 
alternative identified in the Stage 2 EIR/EIS. Making the water rights applications consistent with 
CCWD's proposed action that was addressed in the Stage 2 EIR/EIS will involve reducing the 
quantity of water that can be diverted to storage to 100,000 af, reducing the diversion rate at the 
new supplemental intake from 600 cubic feet per secorxJ (cfs) to 250 cfs, and eliminating the 
Kellogg Reservoir site from the water rights apF)lication. 

CCWD has not proposed or provided environmental documentation under either CEQA or NEPA 
to construct or operate a project other than those considered in the Stage 2 EIR/EIS. In addition, 
CCWD's draft amended water service contract with Reclamation specifically states that "in utilizing 
its CVP water supply in conjunction with its Los Vaqueros water rights water, the District shall not 
deliver within its existing service area. In any one year, a quantity of water in excess of 195,000 
acre-feet." 

Therefore, the total amount of water available for use within CCWD's service area under both Los 
Vaqueros water rights and through CCWD's contract with Reclamation is 195,000 af. 

1-9. The quantity of water diverted to the Los Vaqueros Reservoir would vary annually depending on 

numerous factors, including the amount of storage in the reservoir at the beginning of each water 
year and the availability of flows in the Delta when water quality nnet CCWD's diversion-to-storage 
water quality criterion. Detailed lnformatk)n regarding CCWD's diversions from the Delta under 
each eUtemative is contained in Apperxiix B of the Stage 2 EIR/EIS Technical Report (pages B-8 
through B-86). Attachment 2 to the final EIR/EIS contains detailed information regarding CCWD's 
diversions from the Delta under the revised operations rules for the Los Vaqueros Reservoir 
Alternative. The biological opinions for fish species also contains detailed information regarding 
CCWD's operation of the Los Vaqueros Project with the incorporation of mitigation measures to 
reduce impacts on Delta fisheries. Based on the 57-year simulations used to assess the 
effectiveness of the project altematives arxj their environmental impacts, under buildout water 
demand and extreme conditions, CCWD's total annual Delta diversions could vary from 138,500 
af to 223,000 af. However, CCWD's draft amended water service contract with Reclamation limits 
the anrKMjnt of water delivered to the CCWD service area to 195,000 af/yr. 



A«spons« to Comrrmnts of the U.S. Fish and WildlHe S»ryk» 



5-18 



The net average annual change in Delta diversions resulting from the project is 3,300 af. This 
slight Increase in diversions would occur because of evaporation from the Los Vaqueros Reservoir. 
This evaporation would occur in the system regardless of whether the water were stored in the Los 
Vaqueros Reservoir. 

CCWD has also examined the project for a variety of other scenarios, including operations studies 
tjased on 70-year hydrology (1922-1991). Included were a variety of existing and potential water 
quality and flow standards, including D-1485, Draft D-1630, and D-1485, with the current NMFS 
CVP-OCAP Biological Opinion on Winter-Run Salmon (February 12, 1993) and the FWS CVP-OCAP 
Biological Opinion on Delta smelt (May 26, 1993). Summaries of the results of these studies are 
shown in Attachment 2. The studies show that, regardless of hydrologic period and water quality 
and flow standards, the project does not result in significant net increases in diversions; that the 
diversions in any one year do not deviate significantly from the average diversions; that increased 
diversions generally occur in wet years following dry years; and that decreased diversions are 
common In dry years. 

1-10. The analysis is appropriate and yields sufficient information to draw valid conclusions about project 
impacts. The analysis is based on Central Valley hydrology from 1922 through 1978, not on actual 
flows and demands. The climatic sequence (e.g., precipitation and evaporation) is used as input. 
The water demands are estimates of existing and future conditions. 

Adding current hydrology to the sequence (1979-1991) changes the sample statistics slightly but 
not the conclusions. This is seen in Attachment 2, which shows relevant results of the analyses 
using 70-year hydrology for: 1) D-1485 standards; 2) Draft D-1630 standards; and 3) D-1485, with 
the current NMFS CVP-OCAP Biological Opinion on Winter-Run Salmon (February 12, 1993) and 
the FWS CVP-OCAP Biological Opinion on Delta smelt (May 26, 1993). These results demonstrate 
that, regardless of assumptions concerning Delta standards and the length of the hydrologic 
record, the project has virtually no effect on Delta flows and salinity, and that the conclusions 
based on the earlier studies are unchanged. 

Use of actual 1 979-1 990 export levels is not appropriate because these levels would underestimate 
current and future demand levels (demand levels sometimes exceed export levels). Furthermore, 
actual flows and export levels would not be representative of current and potential water quality 
and flow standards. 

1-11. The analysis contained in the EIR/EIS shows that the proposed action would result in slight 
increases in the volume of reverse flows in the lower San Joaquin River when those reverse flows 
were already occurring because of CVP and SWP diversions from the southern Delta. As shown 
in Figure 3-20 of the Stage 2 EIR/EIS, on the average, the proposed action would result in a slight 
decrease in the frequency and volume of reverse flows in the months of November and August, 
and a slight increase in the frequency and volume of reverse flows in the months of April and July. 
The revised operational plan induded In the biological assessment was developed as a mitigation 
measure for the proposed project may slightly alter the specific results described in the draft 
EIR/EIS but will not change the conclusions. See the 'Mitigation Measures' section of Chapter 
4, 'Delta System Fisheries* for discussion of this Issue. 

The analysis for other conditions (70-year hydrology for: 1) D-1485 standards; 2) Draft D-1630 
standards; and 3) D-1485, with the cun-ent NMFS CVP-OCAP Biological Opinion on Winter-Run 
Salnron and the FWS CVP-OCAP Biological Opinion on Delta smelt) shows that the project effects 
on reverse flows are very small, regardless of the assump)tions on hydrology and Delta standards, 
(see Attachment 2.) 



Response to Comments of the U.S. Fish and Wildlife Service 

5-19 



1-12. The biological assessment for the Los Vaqueros Project, available from CCWD, contains detailed 
Information regarding the estimated levels of fish entrainment at CCWD's existing facilities. CCWD 
and Reclamation believe that the impact analysis contained in the EIR/EIS is adequate to 
determine the significance of project-related impacts. The biological assessment for the Los 
Vaqueros Project, also contains additional infomnation regarding measures proposed by CCWD 
to reduce impacts on Delta fish species. Also, USFWS has issued a biological opinion for Delta 
smelt that also addresses longfin smelt and Sacramento splrttall and finds no jeopardy to the 
species exists. 

1-13. Comment noted. 

1 -14. The specific impact referenced in this comment relates to the effects of the proposed action on 
Delta Cross Channel diversions and related effects on fish migration and sun/ival. The discussion 
on page 4-24 of the EIR/EIS explains that because of specific operational rules in the model 
simulations on which the Impact analysis is based, very small changes in calculated Delta outflow 
can cause changes in the simulated operation of the Delta Cross Channel. In fact, Delta outflow 
is not measured and the proposed action would have very minor effects on Delta Cross Channel 
diversions and flows in Georgiana Slough. The impact analysis on page 4-24 recognizes, however, 
that these minor changes in flow would contribute to significant cumulative effects on chinook 
salmon. 

1-15. CCWD and Reclamation recognize that the Delta smelt population has declined from peai< 
population levels that occun-ed in the 1970s, and CCWD is committed to operate the proposed 
project to minimize effects on this species. The biological assessment fully analyzes and 
describes the effects of the proposed project with mitigated operations on the Delta smelt. Since 
the date of the comment letter, USFWS has issued a biological opinion finding no jeopardy to the 
Delta smelt. 

CCWD and Reclamation recognize that the proposed project would contribute slightly to significant 
cumulative impacts associated with additional diversions projected under the No-Action Alternative. 

1-16. The Stage 2 EIR/EIS does not discuss a "peripheral-type" canal as a mitigation measure. The 
referer>ce on this page to construction of a new Delta Cross Channel connection at a location 
where fish could be screened effectively is not necessarily tied to construction of a canal around 
the Delta. In addition, as stated in the introduction to this section of the Stage 2 EIR/EIS on page 
4-51 , Reclamation, the state, and CCWD are not proposing to implement the measures described 
to mitigate the impacts described under the No-Action Alternative. The purpose of the discussion 
of these mitigation measures is to clearly differentiate between those impacts and related 
mitigation measures that result from simulated changes in background conditions and those 
Impacts that are a direct result of implementing the alternatives considered in the Stage 2 EIR/EIS. 

1-17. As a result of comments received on the draft EIR/EIS, meetings with the various resource 
agencies, and a formal Section 7 consultation, CCWD and Reclamation have developed mitigation 
measures that not only reduce impacts to Delta resources, but actually improve conditions as 
compared to no project. These measures consist of revisions to the proposed project operations 
in terms of the timing and nr^gnltude of diversions ft'om the Delta. Under the proposed mitigation 
plan, CCWD will use a portion of the water stored in the Los Vaqueros Reservoir in lieu of direct 
diversions from the Delta during the winter-run chinook Seilmon's season of highest vulnerability. 
This operation will allow CCWD to eliminate all Its diversions from the Delta, including those from 
Its existing intake at Rock Slough, for a total of approximately 30 calendar days Ijetween March 
15 and May 15 of each year. In addition, CCWD will generally not fill the Los Vaqueros Reservoir 
between March 15 and May 31. 



Response to Comments of the U.S. Fish and Wildlife Service 



5-20 



The revised project operations are fully described in the biological assessment for the proposed 
project as are the effects of the revised operations on special-status fish species. The mitigated 
operations are also described In Chapter 4 of the final Stage 2 EIR/EIS, along with a discussion 
of effects on other fish species. USFWS has also Identified further operational measures to 
minimize Impacts in its biological opinion for Delta smelt. 

1-18. As a result of modifications to the centerline design of the relocated Vasco Road since publication 
of the draft Stage 2 EIR/EIS, the road no longer affects special-status plant populations. No other 
project features would affect special-status plant populations. 

1 -19. Comment noted. Detailed mitigation plans for wetlands and oak woodlands include criteria that 
address the expected temporal loss of habitat values and these criteria are incorporated into the 
mitigation objectives. Surface water ponding In the project area Is highly variable and is generally 
related to specific rainfall events and site-specific soU and groundwater conditions, not annual 
rainfall. Storm events can cause ponding even during extremely dry years and ponding may be 
minimal even during wet years if rainfall during specific storm events is moderate. The 
replacement habitats will be designed to provide the ability to porxJ water in a manner similar to 
the specific habitat areas affected. 

1-20. As noted under "Success Criteria' on page 7-38, proposed success criteria Indicate that success 
would be achieved when: 

■ total vegetative cover exceeds 80% of the amount of cover at the reference sites and 

■ dominant and characteristic species in referenced habitats comprise 80% or more of the 
vegetative cover and greater than 50% of the invertebrate fauna. 

CCWD does not believe that many of the mitigation methods being employed are highly 
experimental. The proposed mitigation program specifically recognizes that the creation of some 
specific habitat types would be difficult and experimental and therefore proposes to mitigate for 
these habitats using out-of-i<ind creation of less complex habitat types to provide no net loss of 
wetland acreage and to recover lost values through a combination of enfiancement, restoration, 
and purchase and protection of high-quality sites. These methods have been employed at pilot 
test sites in the Kellogg Creek watershed for the last several years and have proven highly 
successful. CCWD therefore believes that monitoring periods of 5-7 years are generally 
appropriate but has agreed to monitor mitigation sites for 10 years. 

A detailed wetland mitigation plan has been prepared and is included as an appendix to the final 
EIR/EIS. 

1-21. Comment noted. See response to comment 1-2. Lx>ggerhead shrikes were frequently observed 
during flekJ surveys and the F>roposed jxoject would result In some loss of shrike foraging habitat. 
This Impact is considered less than significant because the project will protect and provide several 
thousand acres of suitable foraging and nesting habitat. Suitat)le spadefoot habitat does not exist 
in the project area. In addition, no spadefoot adults or larvae were observed during surveys for 
special-status aquatk; invertebrates and vertebrates. 

CCWD has conducted detailed surveys for Alameda whipsnakes in suitable habitat in the Kellogg 
Creek watershed and relocated a potential quany site to avokj Impacts on this species. As 
indk^ated In the biological assessnient, the proposed actkxi woukJ have no effect on this species. 

1-22. Comment noted. See response to comment 1 -4. All of the project area where kit fox habitat 
requisites exist is conskjered kit fox habitat and was addressed as such in the biological 
assessment. 



Response to Comments of the U.S. Fish and Wildlife Service 

5-21 



1 -23. Comment noted. Mitigation measures proposed In the biological assessment and required by the 
btoJoglcaJ opinion indude compensation for kit fox habitat Including grasslands, valley oak 
woodlands, and dryland farmed larxj. 

1-24. Comment noted. See response to comment 1 -4. 

1-25. ComrT>ent noted. The t>io)ogical assessment indudes a detaUed analysis of the effects on kit fox 
of direct habitat loss, fragmentation, increased mortality, and reduction in adjacent habitat quality 
from the relocated Vasco Road. Also Induded are mitigation measures designed to avoid, 
minimize, and compensate for impacts. In addition, at the urging o* DFG and USFWS, CCWD has 
agreed to purchase mitigation lands in the Herdlyn watershed area to compensate for habitat loss. 

1-26. Comment noted CCWD does not plan to develop, or lease lands for others to develop, wind 
energy conversion systems on lands for which CCWD owns the wind energy rights. However, 
CCWD generally does not propose to purchase wind energy rights on lands that already have 
leases for wind energy development In place, which Indude some of the lands within 2 miles of 
the Los Vaqueros Reservoir. The creation of a resen/oir could attract bald eagles to the project 
area and make them vulnerable to Increased mortality caused by wind energy development. The 
biological assessment thorougNy discusses this issue. CCWD and Reclamation believe that 
addressing this impact Is the responsibility of wind energy producers in the project area. Wind 
energy producers and the Califomia Energy Commission are actively addressing this impact. 
Possible measures Indude making the wind turbine blades more visible, Installing insulating 
devices and modified crossarms, and revising pde configurations to reduce collisions. The 
tMological opinion for terrestrial species identifies measures to minimize any indirect impacts on 
bald eagles associated with the reservoir. 

1-27. Comment noted. CCWD has stated that active bun-owing owl dens will be avoided during the 
Ijreeding season with appropriate buffers. Possible or known burrowing owl dens will not be 
excavated without USFWS and DFG concurrence and recommendations on the appropriate 
procedures to follow if owls are present. 

1-28. Comn>ent noted. CCWD and Reclamation have fully analyzed impacts on Califomia tiger 
salamanders that could result from the proposed project induding the reservoir and the relocation 
of Vasco Road. Mitigation plans have tjeen designed that take into account both life stages of this 
species. These mitigation plans have been provided to USFWS and DFG in the biological 
assessment for terrestrial species transmitted by Redamatlon on June 1, 1992, and are being 
further refined. 

1-29 Comment noted. CCWD and Redamation have fully analyzed Impacts of project implementation 
on tfwse species. Mitigation plans for terrestrial species have t)een more fully developed and 
provided to USFWS In the biological assessment transmitted by Redamation on June 1, 1992. 

1 -30. Only one population of vernal pool fairy shrimp (Branchinecta lynchi) could be affected by the 
proposed project. This population occurs In a large rock outcrop vernal pool at the eastem edge 
of the watershed. Potential Impacts on this species are related to the relocation of the natural gas 
pipelines, which could result In temporarily Increased access to the sites by construction workers. 
CCWD believes that mitigation measures proposed in the Stage 2 EIR/EIS and further expanded 
In the biological assessment for terrestrial species are adequate to protect this species from any 
potential Impacts. Since tfie date o^ the comment letter, USFWS has issued a draft conference 
opinion finding no jeopardy to the three fairy shrimp species. 

1 -31 . Comment noted. CCWD recognizes that these species are sensitive and has identified mitigation 
nr>easures to reduce impacts on these species to less-than-significant levels. The biological 
assessment for terrestrial species provides additional Information on impacts and mitigation 



Response K> Comments of tfw U.S. Fish and WildliM Service 

5-22 



measures for these species. CCWD will be actively managing the Kellogg Creek watershed and 
will have substantial opportunity to address impacts on these species. CCWD will consider the 
need for pilot mitigation studies and will continue to consult with both DFG and USFWS regarding 
the need for such studies. 

1-32. The Kjelson model was developed based on information for fail run during April-June. The model 
is the best tod available to evaluate effects of flow splits and export level on chinook salmon 
survival during migration through the Delta. Application of the nxxjel to other runs is probably not 
a significant departure from applicatk>n to fall run because all chinook salmon have similar 
migration behavior and temperature requirements. Appik:atk>n outside the April-June period, 
however, could result in significant bias. 

The main bias would be the effects of temperature and survival through the Delta via the Delta 
Cross Channel and Georgiana Slough. Temperatures woukJ be less than 59°F during November- 
March and temperature-related nxxtality would probat)ly rx)t occur. Also, agricultural diversions 
are much lower during November-March than during April-June. Consequently, mortality during 
migratkxi through the Delta during November-March may be overestimated by the Kjelson model. 
The result may be that application of the Kjelson model to November-March will result in higher 
estimates of mortality than would actually occur. 

The PTHxlel, however, indicates that rrwrtality of chinook salmon juveniles migrating via the Delta 
Cross Channel and Georgiana Slough is greater at high export. Therefore, increased diversion 
causes increased mortality. Although the change in mortality rate resulting from increased export 
during November-March may be overestimated, the model is an adequate tool for comparing 
alternative operations that prinrarily affect the volume of export. 

1 -33. CCWD has reviewed the referenced infomnation and determined that It does not change impact 
analyses or conclusions. 

1-34. CCWD believes that the information contained In the Stage 2 EIR/EIS, the biological assessment 
for the Los Vaqueros Project, and the various mitigation plans that have been developed in 
conjunction with DFG, USFWS, NMFS, and the Corps provide detailed information regarding 
project operations and project-related impacts and benefits. The revised operations developed 
as mitigation for the proposed project and presented in the biological assessment for fish species 
(submitted to the National Marine Fisheries Service and the U.S. Fish and Wildlife Service on 
August 25, 1992), combined with addittonal measures imposed by USFWS through consultation, 
substantially reduce impacts on fish species as compared to the no-project condition. See also 
response to comment 1-17. 

1 -35. Formal consultation on the endangered San Joaquin kit fox was initiated on June 1 , 1992. Formal 
consultatk>n on the Delta smelt was initiated on April 7, 1993. Consultation on these species was 
coTKduded in September 1993. The results of this consultation are summarized in Chapter 20, 
"ConsultatkMi and Coordination". 



Response to Comments of the U.S. Fish and WildlUe Service 

5-23 



0S:£T HOW .36- T I -AH. J 

LETTER NO. 2 ^ 

•'a\vsvteb states environmental protf^ction agency ^ 

r^^; REGION IX ^^ ^ 

^^mm^i 75 Hawthorne Street 

^'^ '-^^^ San Francisco, CA 94105 ^ ^^ 

Roger Patterson ^ 

U.S. Bureau of Reclamation 

Mid-Pacific Division » 

MP-750 W 

2800 cottage Way 

Sacramento, CA. 95825 

Dear Mr. Patterson: ^ 

Th. Environmental «f -^^^ ^^e^Uentil'^^Sp^t'iraLS^t ■ 

Draft Environmental I"P»=^ ««P°'^*(^":'n"L:f ^^.^^os ProJ.ot, ■ 

rnvS:nr.^t:rJuKir(rBSrraPj?|or<io Cr^-Parts 1.00-X=0S, I 
and section 309 of the Clean Air Act. 

^'^%s°""\rtfc.Tar«''ifp^uea'fo"?i/Lrtr?^?\o° ■ 

improve the quality of *'^^®^.°„PP/;;„___ _>d to improve the 

minimize seasonal water qualxty -5-?-,-^^^°,^,? supply storage | 

reliability of its water supply ^y p ^^^^ ^^^^^^ emergencies ■ 
within the Kellogg C^®®'^,^^^ J^Vii-x and for blending with low 

diversions an« vaqueros Reservoir to operate. ■ 

order to allow ^^T^I^L in^detail are no-action existing ^ 

^:ranrtfon p ^ r c. -|Si-n--f--LSr.''-f "- " 

''^JtincCmuiativefu^ure conditions considers maximum water ^ 
r ind nlus buildout of proposed facilities (e.g., the State 

Sa?er P?iiect (SWPrNorth and South Delta projects, Los Bancs I 

Water P^°J*J;^^ J^^' -ir alternatives include the evaluation of P 
cl^en'al^ernati" new Intaie Ind pipeline configurations. The 

pj^ferred alternative is the Los Vaqueros Reservoir wxth a new . 

sSpptemental intake at Old River No. 5 site. 1 

We commend CCWD and BOR for the well organized and detailed ^ 
EIS Sf special note are the clear statements of evaluation 2-1 

methodology, level of significance criteria and mitxgat.on « 

'■^' RECEIVED I 



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H OU c 6 - I T - A y W 



suggestions. We appreciate the inclusion of three no-action 
scenarios which allow comparisons with existing, future, and 
cumulative future water supply demand conditions without the 
project. Furthermore, we are pleased with the effort to 
recommend mitigation for potential impacts of the no-action 
future and no-action cumulative future conditions. 



EPA believes it is important to develop water supply 
strategies which ensure the availability of water to meet 
protective water quality standards for the San Francisco Bay and 
Sacramento River and San Joaquin River Delta (Bay/Delta) and to 
protect aquatic resources and endangered species. It is our 
belief that projects predicated upon increased Delta exports 
should not be committed to until completion of the State Board 
hearings. Although this project does not propose a large 
increase in Delta diversions, we are concerned with the 
evaluation and approval of this project prior to adoption of 
protective water quality standards for the Bay/Delta by the State 
Water Resources Control Board. We therefore recommend deferring 
approval of this project until final adoption of protective water 
quality standards for the Bay/Delta unless it is clearly 
demonstrated that the project will not adversely affect the 
designated beneficial uses of the Bay/Delta estuary. 

The project proposed by BOR and CCWD would allow CCWD to 
increase diversions from the current level of 135,000 acre feet 
(af)/yr (pg. 2-1) to the full BOR allocation of 195,000 af/yr 
(pg. 2-13) by removing physical constraints in the CCWD delivery 
system. The reservoir storage alternatives appear to be based on 
the premise that there are "surplus" flows during the winter and 
spring months available for export into the reservoir without 
impairing compliance with water quality standards or affecting 
beneficial uses. The shift in pumping to the winter may be 
environmentally sound pyovidegl there is no net increase in 
exports that may conflict with protection of the Bay/Delta 
ecosystem and endangered species resources. Assuming that under 
certain conditions there is water in excess of the flows required 
to meet water quality standards and protect the aquatic ecosystem 
during wetter months, it is important to recognize that this 
water may be needed to meet water quality standards in other 
seasons. The FEIS should clearly specify the criteria that will 
be used for diverting unregulated outflow and flood flows and 
evaluate how the amount of available "surplus" flows would be 
determined. 



2-2 



2-3 



The evaluation of water supply potential is based on water 
quality standards and flows recognized in D~1485 which do not 
adequately protect beneficial uses in the Bay/Delta and which are 
being revised through the current State Board proceedings 
scheduled for completion at the end of 1992. Since these 
standards are no longer considered adequate to protect the 
estuary, they do not provide an appropriate baseline for 
determining the availability of unregulated water for storage. 
We believe the project and EIS should treat revision of water 
quality standards as "reasonably foreseeable." 



2-4 



5-25 



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Other areas of concern to EPA are potential Impacts to 
fiahariea, wetlands and air quality. Based upon our review of 
the DEIS, and the above concerns, we have classified this DEIS as 
category EC-2 , Environmental Concerns - Insufficient Information 
(see enclosed "Summary of Rating Definitions and Follow-Up 
Actions") . Although this project does not propose a large 
increase in Delta diversions in comparison with other proposed 
water supply strategies which we have rated more severely, we 
still have strong concerns with potential impacts to fisheries 
and the need for a firm commitment to mitigate for these impacts. 
We also emphasize the need to clearly demonstrate that the 
project will not conflict with the availability of water to meet 
existing and reasonably foreseeable future protective water 
quality standards for the Bay/Delta and its beneficial uses. Our 
detailed comments are enclosed. 



i 



2-5 



We appreciate the opportunity to review this DEIS. Please 
send three copies of the Final EIS to this office at the same 
time it is officially filed with our Washington, D.C. office. If 
you have any questions, please call Jacqueline Wyland, Chief, 
Office of Federal Activities, (415) 744-1584 or Laura Fujii, of 
her staff, at (415) 744-1579. 




Deanna Wieman, Director 
/ Office of External Affairs 

Enclosure; (10 pages) 

Filename: LVAQDEIS.LTR 

92-069 

MI000323 

cc! BOR, Doug Kleinsmith 
FWS, Wayne White 
COE, Colonel Sadoff 
CCWD, Jemice Hutton 
CCWD, Jones & stokes, Gary Darling 
SWRCB, Ross Swenerton 

RWQCB, Central Valley Region, F. Wayne Pierson 
BAAQMD 
ARB 



5-26 



S0"d Se9It-t'i9It' 2S:£T N0Nc6-M-AUW 

POLICY AND PROCEDURES ^^^^ 



1U73784 



SO»»(A** Of HATIHC OEKINITIOWS 
ANO fOLLOW-UI' ACTION* 

Envtrona«n<«l (■P4ct «l ttx AcOon 

LO — -Lack at Ob^eoclona 

Th« C?A raul«w h4a n«t 14«nti<l«d any potancltl •nwlronaantal t*p*«ta 
ra^ulrtng aukacanctva cK«n(«a to «h« pcvpoaal. Tha ravtaw say hava HUcloaad 
«pp«rcunlttaa for ayplleacion «f atclxatlon aaaauraa thac could taa 
aeeoaplt«h«4 with n« aer* th«n •tnor changaa (o cita propoaaU 

tC— tAvlrenoantal Cencarot 

Tha IPA (avlaw lui t4aati(t«4 aQvlroawacal tafa«ta that aho«il<i b« avoUa^ la 
araar to (ully ^ecaat tha aavtraaMet. Corractlva aaaauraa say ra^ulra 
«haB|aa ta tha prafarra4 altarnatlwa ar appllcattaa «f •ltl«atlen Ma«ur«« 
that can raduca tha anvlMBMatal la^aet. ETA vinU Uk* t9 vork "ttH th« 
l««d «g«ncr to r«<iuc« Ch«*« Uif«ct«< 

(0~Cnvlrofla«nc<l Ob]««ttoM 

Tha (PA ravlaw ha* 14antlfl«<i alfiilfleant aflwlroMMittat t«p«ct« that mt*t b« 

ivaUa4 in ardar to prowld* ada^uata pretaetlan for tho anvtroflaant. Corr4«tl«« 

■aaauraa aay ra^ulra aubacaattal chaa«aa ta tha ptafarrad alcatna tlwa or 

eenttdaratlan o( aoaa othor p«oJ««t altarftaclwa (laeludlac tha no actloit 

«U«rnat1«4 or a naw altonuttva). >PA lacanda ta «Mrk with tha Uad 

a(an«y to raduca thaaa iapa«t*< 

(U— (nvlrooaantaliy Uaaat la factory 

Tha (PA ravlaw haa tdaatt(ta4 advacaa anvtroaMittal lapaata that ata of 
auf flalant sagitltuda that thay ar« miaatiafaatacy (re« tha ot«n4polnt of 
public haaleh or «al(«r« or awvl r a— antal quality. EPA Intanda to Msrk with 
tha Uad a«anay to raduca thaaa ta#acta. If tha potantlai anaatltfactery 
lapaela arii not corractad At tho fUal CIS ataaa, thl* propoaal wilt ta 
racoaaandad for rafarrai to tha Cfi<). 

AdaauacY of tha lapact Stataaant 

Catagory I— Ada^uata 

tPA ballavaa tha draft CIS ada^iutoly dot* forth ch« dnvtrooMacdl lBpact(<) 

of tha prafarrad altarnativa and Choda of tha altarnatlvaa raa>on«blx avail 

abla to tha ^rojaet ae action. Mo farthar analyil* or data collactloo t« 

aaaaaaary, but tha tavlawar say autgaat tha addition of aiarlfylng lanfuafo or ■ 

InforaaClon. 

Catagory 2— Inauf f lelaat lafatvatlon 

Tha draft IIS doaa oot aantaln aufftdaat Infaraattao for CPA to fully aaaaaa 
anvlronaantal tspaeta that ahauld ba awoldad In ordar to fully protact tha 
anvlronaanc, or tha tPA rovtovar haa Idantlflad naw raaaoaably avallabla 
altarnaclvaa that ara wtthla tha apoettini of altaraatlvaa analyaad In tha 
draft EIS, which could rad«i«4 tha anvlronaantal lapactt «( tha a«tton. Thd 
Idantlflad additional Inforaatloa, data, analyaaa, or dlaauaalon ahould ba 
Includad In tha final lit. 

Catagory )"lnada^uata . 

EPA deaa not b«lUv« that ttta draft CIS a^cquataljr ata«aa«s petandally 
tlgnlflcant anvlraaaantal lapaott of tha action, or tha (PA ravlawar haa 
Idantlflad naw, ^aaaanably avallabla aliarnatlvaa that ara autalda of tho 
apactrua o(> altarnatlvoa analyaad In tha draft CIS, which ahould ba analyaad 
In ordar to raduca tha potentially algnlflcant aovlronaaotal lapaata. (PA 
ballavaa Chat tha Idantlflad additional Inforaatlen, data, analyaaa« ar 
dlaeuaalona ara of ouch a aagnltuda that thay ahould havo full public ravlaw 
at a draft ataga. CPA doaa not ballava that tha draft CIS la tdaqutta far tha 
purpoaaa of tha HEPA and/or Soctton )09 ravlaw, and thua ahould ba (orsally 
raviaod and aada available for public eoaaant In a aupploaontal or ravtaad 
draft CIS. On tha baata «f (ha petontlal algnlflcant iapacta Involved, thla 
propoaal could ba a candidate for referral to the C(9. 

ofroa (PA Manual 1640 Policy and Procaduraa for tha Ravtaw of Paderal Aationa 
lapaeclng cha linvlroaaant. 



Figure ^'^^ 



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PA COWEHTS- BOB. DEIS LO S VAQUEBOS RtSCRVOlR. HAT 1992 



COMMENTfl 



NATIONAL ENVIRONMENTAL POLICY ACT 

Alternativea Analysis 

A number of projects are being proposed to increase storage 
of "surplus" Delta flows. As stated in the DEIS, the Los 
Vaqueros site is capable of providing greater capacity than the 
proposed 100,000 af. EPA is aware of CCV?D efforts to encourage 
participation by other agencies to achieve benefits that could be 
realized from a joint-participation project. We believe further 
evaluation of an enlarged joint-participation proposal may be 
beneficial and urge other agencies to consider the Los Vaqueros 
Bite as an alternative for other potentially more damaging 
proposals. 

cumulative Impacts 

It is our understanding that the evaluated Kellogg Reservoir 
alternative, located downstream of the proposed project, would 
not be precluded by construction of Los Vaqueros Reservoir. The 
FEIS should address the feasibility of later development of 
Kellogg Reservoir. If such development is "reasonably 
foreseeable," the FEIS should evaluate the cumulative impacts of 
this future development. The FEIS should also address the 
potential for an eicpanded Los Vaqueros Reservoir versus later 
development of Kellogg Reservoir. 

The DEIS does not appear to address the cumulative impacts 
of the Corps of Engineers' proposal to reoperate Folsom Reservoir 
for 10 years. Folsom Reservoir reoperation would increase the 
allocation of storage space for flood control therefore reducing 
firm yield water supply, hydropower, and operational flexibility 
to meet Bay/Delta water quality standards. The FEIS should fully 
evaluate the potential cumulative impacts of Folsom Reservoir 
reoperation taken together with this project, in accordance with 
40 CFR 1502.16 and 1502.8. 



■ 



2-6 



■ 



2-7 



2-8 



WATER RESOURCES 

water Quality Comnenta 

1. The probable availability of "surplus" Delta flows should be 
estimated. The proposed project could increase competition among 
existing and planned projects for diversion of unregulated Delta 
outflow. Although the DEIS examines the no-action cumulative 
future condition (CVP/SWP buildout and maximum water demand) , the 
DEIS does not appear to address the feasibility for these 
projects to simultaneously divert this "surplus" without 
impairing compliance with current and potentially more stringent 



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future water quality standards. In fact, the DEIS evaluation of 
the no-action cumulative future condition appears to indicate 
Bignificnnt reduction in Delta inflow and outflow and CVP/SWP 
reservoir storage levels even without the proposed project (pg. 
3-23) . Even though Los Vaqueros may cause very small incremental 
changes to Delta conditions in comparison with the no-action 
future and no-action cumulative future conditions (pg. 3-32) , we 
remain concerned with the cumulative affect on the Bay/Delta. We 
believe the issue of feasibility for simultaneous diversion of 
"surplus" flows is critical in determining potential adverse 
impacts to water quality of the Bay/Delta and should be addressed 
in the FEIS. 



2. We recognize that the likelihood of new water quality 
standards makes it difficult to predict changes in operations and 
structures of the CVP and SWP. Nevertheless, these changes will 
certainly occur. Two future scenario impacts are likely: (1) the 
greater flexibility in water diversions by CCWD as a result of 
Implementing the preferred alternative could be beneficial to 
fishery resources if operation is restricted during 
environmentally sensitive months or (2) the increased 
entrainment, transport, or delay of fish within the Delta would 
be detrimental. 



2-10 



Overall, the negative impacts of this project appear minor 
relative to the expected degradation of the estuary if the only 
future change were to be the increase in total diversions as 
outlined under the no action future conditions scenario, which 
includes the projected increase in water use by CCWD. The DEIS 
describes a number of measures which would reduce the future 
degradation of the estuary and builds a case that the operation 
of the reservoir would be consistent with these possible changes 
and would, by itself, reduce some of the adverse impacts of the 
present system during dry and critical years. A stronger 
argument for environmental benefits can be made by using some of 
the capacity of Los Vaqueros to reduce the present effects of 
year-round operation of pumping at the current intake. A 
stronger case for environmental protection could be made by 
proposing to restrict pumping during sensitive periods except 
under some sort of emergency schedule when the reservoir is 
critically low. 

3. The use of a future scenario which assumes the full build- 
out water demand of 195,000 acre-feet may be unrealistic since 
this demand may not be satisfied under the assumption of no 
project. Furthermore, enlargement of the Contra Costa Canal as 
an alternative way to provide for increased water demand (pgs. 
18-12 to 18-14) may not be effective given the acknowledged 
existing difficulty of meeting acceptable water standards. We 
recommend the environmental cost of the project be clearly 
separated from the impact of projected water demands. 



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4. Considerable discussion has occurred over the CCWD permit 
applications to pump larger quantities of water and for increased 
water right allocations totalling far more than the 195,000 acre- 
feet specified in the DEIS. The FEIS should address these 
issues. If pumping surplus water to fill the reservoir will 
reduce CCWD ' s need for contracted water, mitigation measures 
using this uncommitted water should be evaluated. 

yishertaa Gemments 



2-13 



General Comments 

1. The principal concerns of project operations involve their 
contribution to the decline of fishery resources in the Delta and 
Bay. These concerns center on the displacement or entrainaent of 
upmigrating epawners or of outmigrating young and larvae. For 
Delta smelt and longfin smelt the months of particular concern 
are from January to June; for striped bass young the months of 
particular concern are from April to July and from September to 
November; for American shad the adults are susceptible from July 
to August and the outmigrating young from October to December; 
and with four different runs, Chinook salmon pass through the 
Delta in most months of the year both as adults and as 
outmigrating smolts. 

Project operations would reduce CCWD pumping needs during 
times when water quality at the current intake is below municipal 
and industrial criteria (>65 mg/1 chlorides and >50 mcj/1 sodium) . 
Reservoir filling would occur when water of high quality is 
available at the new supplemental intake between the months of 
November and June, inclusive. Water from the reservoir would be 
used to extend the emergency supplies of CCWD and for blending 
during the summer with lower quality water from the current 
intake at Rock Slough, The reservoir level is expected to 
fluctuate from 5 to 15 feet. Because of the months of operation, 
the principal delta species affected will be winter-run chinook 
salmon. Delta and longfin smelt, and striped bass. 

The proposed mitigation for Increased entrainment at CVP/SWP 
Delta export locations (Impact 3 in Table S-l) is not appropriate 
for delta smelt. Closing of the cross-delta channel is more 
likely to be detrimental for this species in most years since 
gate closure would increase the strength and frequency of 
reversed flow in the lower San Joaquin. Furthermore, delta smelt 
do not pass this location. 

2. The Kellogg Creek drainage fishery effects of Los Vaqueros 
construction and operation appear to be minor since the fish 
fauna is small and not composed of any species of special 
concern. The proposed mitigation offers ample opportunity to 
limit downstream construction effects. 



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3 . The reservoir is not expected to be emptied except in 
extremely rare, emergency events. The DEIS should evaluate the 
number of times in the historical hydrologic period that CCWD 
would have been able to satisfy its water supply and water 
quality needs without Delta diversions during the sensitive 
months for fisheries. Potential impacts of the project would be 
minimized if CCWD removed these months of sensitivity from its 
proposed pumping schedule, rather than offering to reduce or 
curtail pumping during these months as a possible mitigation 
measure . 



2-16 



4. We recommend CCWD reduce the water diversions at the 
existing Rode Slough intake for the Contra Costa Canal during 
months of environmental sensitivity (March-May) and rely more on 
Los Vaqueros reservoir water in years when the reservoir could be 
filled before March. This could provide significant 
environmental benefits. 



2-17 



5. The future conditions (other water projects and standards) 
in which Los Vaqueros will operate are hard to define and CCWD 
has made a good attempt to look at effects of future changes - 
the increased demand for water and buildout of CVP/SWP 
facilities. However, CCWD's comparison of Los Vaqueros effects 
with a future of increased diversions may lead to inappropriate 
conclusions. An example is the attribution of greater survival 
of salmon and striped bass in some months despite increased 
diversions. This arises because the emptier reservoirs could 
hold more spring runoff, which would lead to lower springtime 
river flow and less diversion at the time salmon would be 
outmigrating (personal communication with Greg Gartrell of CCWD) . 
This scenario would facilitate smolt migration through the delta 
to some extent — but at the expense of lethally high temperatures 
upstream. If none of the eggs survive, efforts to reduce smolt 
entrainment are useless. It is particularly questionable to 
refer to such decreased entrainment as an occasional beneficial 
effect that would be most pronounced in dry years since those 
years would probably have the highest upstream temperatures, 

6. North Delta, South Delta, and Los Banos Qrandes are proposed 
future changes to the system which would enable withdrawal of 
some of the water that CCWD proposes to withdraw. How would that 
"competition" affect the presumed benefits of greater flexibility 
in water withdrawal by Los Vaqueros? 

7. An "isolated facility" of some sort is a potential future 
condition. How will that affect getting water to the various 
alternative CCWD intakes? How will that amplify the impacts of 
water removal by CCWD on flow in the western delta? 

8. New standards of salinity and temperature will be enacted in 
the near future and will be more restrictive than D-1485. 



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Consultation with State Water Resources Control Board staff could 
identify problems with meeting current and future water quality 
standards with implementation of Los Vaqueros . A description of 
potential problems with attaining water quality standards for 
various levels of desired emergency supply and chloride/sodium 
reduction should be provided in the FEIS. 

9. Positive net flows from January to June at Antioch seem to 
be one of the more likely constraints on CCWD operations. Can 
the effects of different intake sites be evaluated in this 2-22 
regard? Will the more southerly location of the alternative 
intake reduce the impacts of the current intake on flows in the 
lower San Joaquin? 

10. On a broader view, future scenarios that encompass the most 
recent versions of the alternatives IV-VI in the State Water 
Quality control Board's hearings would provide the best possible 
estimate of Los Vaqueros' impacts. Alternative IV (in its 
present configuration) would provide a likely scenario of minimal 2-23' 
protection, and V would provide a more protective set of 
standards. Since these represent two identifiable and legally 
required sets of goals, they are reasonable standards to use to 
'box' the standards that will be set, for purposes of NEPA 
analysis. 

11. Temperature is unlikely to be controllable by project 
operations in some year types but is likely to be controllable in 
important months of other year types. How will project 
operations of CVP and SWP to meet temperature standards be 
affected by CCWD; or might CCWD's ability to take water be 2-24 
curtailed by federal and state agencies to meet a temperature 
standard? This will be difficult to address. We suggest that 
Sheila Green of DWR or Jack Rowell of Reclamation might be able 
to give some guidance on how important CCWD's role might be. 

Specif io comments (DEIS pgs. S-9 to S-10) 

1. The increase in suspended sediments due to construction will 
be mitigated by utilizing containment structures to restrict 2-2! 
release of sediments. This appears to be adequate mitigation for 
what should be a minor fisheries impact. 

2. The disturbance or removal of resident fish habitat at the 
new intake would be mitigated by avoiding or replacing riparian 
and aquatic vegetation. This appears to be adequate mitigation 
for what should be minor fisheries impact. 

3 . The DEIS describes increased reservoir fisheries habitat as 
a beneficial impact. These are generally exotic species that are 
doing well in many other areas thus the ecological benefit of 
having more of them is slight. The increased recreational 



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fishery opportunity is a tangible human benefit, but should not 
be compared to the detrimental impacts on native fisheries in the 
Delta. The reservoir might be of value as refuge habitat for 
some native species with reduced populations, particularly 
Sacramento splittail, blackfish, and hitch. Although tl\e lake- 
dwelling subspecies in Clear Lake is extinct, it demonstrates 
that the fish is probably capable of survival in a reservoir like 
Los Vaqueros. 

4. The DEIS describes reduced survival of chinook salmon and 
increased entralnment of all runs (including the winter-run) due 
to cumulative diversion impacts in some months & reduced survival 
of striped bass eggs and larvae and delta smelt larvae and 
juveniles due to reduction in net San Joaquin River outflow. 
Mitigation which is within the power of CCWD to perform should 
be required. For example, the CCWD should avoid pumping during 
sensitive months unless or until other mitigation conditions are 
made by other agencies. 

flection 404 Comments 

Mitigation 

The section on mitigation measures (pgs. 7-36 to 7-47) 
adequately describes in a conceptual fashion measures that should 
be taken to mitigate impacts to wetlands. A detailed final 
mitigation plan approvable by resource agencies, EPA, and the 
Corps of Engineers (COE) will need to be completed before the COE 
can issue a Section 404 permit for the project. 

AIR QUALITY COMMENTS 

Planning Requirements 

Contra Costa County is located in a Federal nonattainment 
area for ozone and is in violation of state PMIO standards. The 
DEIS incorrectly states that "the federal PMIO standard is not 
being exceeded in the Bay Area" (pg. 16-6) . Violations of the 
federal PMIO standard have occurred in San Francisco and Santa 
Clara counties in the past year, and EPA will propose 
redesignation of these two counties to PMIO nonattainment during 
1992. In addition, exceedances of tihe PMIO standard have been 
recorded at t:hs Livemore monitoring stations. The DEIS should 
state that Federal agencies are required by the Clean Air Act to 
assure that all actions conform to an approved State 
Implementation Plan. In accordance with section 176(c) of the 
Clean Air Act (42 U.S.C. 7506), 

"No department, agency, or instrumentality of the Federal 
Government shall engage in, support in any way or provide 
financial assistance for, license or peirmit, or approve, any 



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activity which does not conform to an implementation plan 
after it has been approved or promulgated under section 

no." 

Conformity to an implementation plan means: 

to an implementation plan's purpose of eliminating or 
reducing the severity and number of violations of the 
National Ambient Air Quality Standards (NAAQS) and 
achieving expeditious attainment of such standards; and 

that such activities will not (i) cause or contribute 
to any new violation of any standard in any area; (ii) 
increase the frequency or severity of any existing 
violation of any standard in any area; or (iii) delay 
timely attainment of any standards or any required 
interim emission reductions or other milestones in any 
area. (Clean Air Act, Section 176(c)). 

The Bay Area Air Quality Management District and Association of 
Bay Area Governments should be consulted to determine project 
conformity to the State Implementation Plan and Air Quality 
Management Plan. 

The Bay Area Air Quality Management District must prepare 
State Implementation Plans (SIPs) for carbon monoxide (CO) and 
ozone which meet the requirements of the 1990 Clean Air Act. The 
CO SIP is due on November 15, 1992 and the ozone SIP by 1993. 
Furthermore, the San Francisco Bay Area will be proposed as a 
PMio non-attainment area and will be required to submit a PMIO 
SIP 18 months after redesignation. 

Air Quality Impacts 

1. Growth projections should be consistent with the latest Air 
Quality Management Plan and state Implementation Plan. 
Discrepancies indicate potential nonconformity with air quality 
planning requirements and possible violation of Section 176 of 
the Clean Air Act. The DEIS states, "Water demand forecasts used 
by CCWD are based on city and county land use plans that are 
generally consistent with the forecasts used for the BAAQMD clean 
air plan" (p. 16-18) . Since growth in different locations may 
have different air quality impacts, consistency with the overall 
Air Quality Management Plan population projections may not 
demonstrate full conformity. 

2. The DEIS should address whether this project accommodates 
growth in water demand or usage. If so, the emissions from 
potential growth (i.e., traffic related emissions) should be 
quantified and their potential impact on air quality should be 
analyzed. In addition, the DEIS states that there will not be 

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significant impacts to air quality from construction under no- 
action future conditions even though CCWD would improve the 
existing water delivery system to increase capacity. Although 
short-term construction impacts to air quality may be minimal, 
the FEIS should address the issue of growth accommodated, by 
increased system capacity and the potential impacts to air 
quality. 

3 . The quantified emissions from increased energy demand should 
be evaluated to determine their effect on air quality, and 
determine whether the latest emission forecasts in the Air 
Quality Management Plan account for these increases. If 
emissions are not accounted for in the emission forecasts, the 
project could have a significant impact on air quality. 

Mitigation 

1. The air quality analysis on pg. 14-12 concludes that ozone 
precursor and FMIO emissions would exceed the best available 
control technology (BACT) threshold values and contribute 
substantially to regional ozone pollution and localized fugitive 
dust emissions. Therefore, the FEIS should include mitigation 
measures for PMlO and ozone precursors and address their 
effectiveness to control these emissions. Although mitigation 
measures may not be able to reduce potential air quality impacts 
to less~than-significant levels (pg. 14-13), they should be 
presented and implemented as means to reduce and minimize these 
impacts . 

The DEIS states that dust abatement programs would not be 
highly effective (pg. 14-7) . On the contrary, any control 
measures to reduce PMIO should be included to reduce the amount 
of PMIO emissions. In addition to dust abatement programs, the 
FEIS should discuss wheel watering stations and other control 
strategies to prevent PMio emissions. All mitigation measures to 
control dust should be included, or the FEIS should describe the 
rationale behind eliminating a mitigation measure. 

2. On page 14-9, the cumulative effects of simultaneous 
construction period fugitive dust and ozone precursors are 
discussed. The FEIS should address the option of phasing certain 
stages of construction to avoid cumulative significant effects. 

3. Chapter 15 discusses the project's effect on transportation 
systems. The FEIS should address transportation control measures 
to offset the adverse effects of increased vehicular trips for 
construction period trips and recreational trips. 



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CPA CCW4EMTS. «» DEtS LOS y^QIggOS BESCTVOIH. WAY 1992 

QENERAL C OMMENTS 

1. Past actions such as land purchases within the Kellogg Creek 
watershed and proposed Vasco Road and utility relocation appear 
to commit CCWD to the Los VaqueroK or Kellogg Reservoir 
alternatives. The FEIS should address the actions which may 
occur if these alternatives are not approved or if they are 
drastically modified. 

2. The FEIS should describe the status of coordination with the 
U.S. Fish and Wildlife Service pursuant to the Fish and Wildlife 
Coordination Act (48 Stat. 401, as amended; 16 U.S.C. ^61 et. 
seq.). We recommend the FEIS include the U.S. Fish and Wildlife 
Service's Coordination Act Report and Biological Opinions on 
endangered species. 

3. Chapter 17 discusses water service expansion to the East 
County area. CCWD has entered into agreements with the East 
Contra Costa Irrigation District (ECCID) and the City of 
Brentwood to supply treated water to these areas (pg. 17-2) . 
Although the DEIS states that the proposed project could only 
serve this expanded area if new water supply allocations are 
found, the FEIS should address whether the proposed project 
influenced and encouraged these future water service expansion 
agreements. 

4. The FEIS should include information on the substance of 
public comments received in response to past Environmental Impact 
Reports for this project (e.g. Vasco Road and Utility Relocation 
EIR) . 

5. One of the primary goals of the proposed project is to 
provide a reliable emergency supply in the event of a major 
earthquake, levee failure, chemical spill, drought or other Delta 
water quality problems (pg. 1-3) . The FEIS should evaluate the 
effect of the above events (e.g. major earthquake) on other 
essential components of the CCWD system. The availability of Los 
Vaqueros emergency supply would not increase reliability if other 
required conveyance and pumping facilities are also vulnerable to 
the same emergencies. 

6. Table 8-7, pg. 8-31. The wetlands wildlife habitat value 
(41 acres) for the Kellogg Reservoir alternative does not match 
the number of wetland acres (approximately 138 acres) listed on 
Table 7-4, pg. 7-27. The FEIS should explain this difference. 



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Responses to Comments of the U.S. Environmental Protection Agency 



2-1 . Comment noted. 

2-2. CCWD and Reclamation recognize that new water quality standards will be set in the Delta. The 

state is obligated to review such water quality standards every 3 years. (XWD and Reclamation 
believe that the EIR/EIS clearly denrK>nstrates that the Los Vaqueros Project will have no adverse 
affects on the beneficial uses of the Bay/Delta estuary and tfuit proceeding with the Los Vaqueros 
Project is appropriate at this time. 

CCWD currently has almost no storage in its water distritxition system. If a levee failure or other 
event occurred that rendered CCWD's Rock Slough htake unusable, CCWD could meet its 
demands for only several days. This emergency supply need Is not related to existing or future 
Delta water quality standards. 

As a Central Valley Project contractor and holder of state water rights, CCWD would be subject 
to all appropriate restrictions placed on Delta diversions as a result of state water rights 
proceedings and compliance with other state and federal laws and regulations. The Los Vaqueros 
Project would greatly increase CCWD's operational flexibility and could be a valuable addition to 
the Delta water system because the Los Vaqueros Project could allow CCWD to modify its 
operations each year to avokt or reduce impacts on sensitive Delta resources. 

in order to t>e responsive to requests for further information and to keep up with a rapidly 
changing regulatory environment, CCWD has examined the project under a wide variety of current 
and potential water quality and flow standards. Results are summarized in Attachment 2 for 70- 
year (1922-1991) hydrology with: 1) D-1485 standards; 2) Draft D-1630 standards; and 3) D-1485, 
with the cun-ent NMFS CVP-OCAP Biological Opinion on Winter-Run Salmon (February 12, 1993) 
and the FWS CVP-OCAP Biological Opinion on Delta smelt (May 26, 1993). Included in the 
analysis is an assessment of some proposed EPA water quality standards. Under the operations 
discussed in the mitigation plan, these studies clearly demonstrate that the project will not 
adversely affect the designated benefrcial uses of the Bay/Delta estuary. 

2-3. The Los Vaqueros Project does not greatly increase CCWD's ability to divert water from the Delta. 

Although the Los Vaqueros Reservoir would eliminate the need to make improvements to portions 
of CCWD's Contra Costa Canal system, other major restrictions would still exist in the CCWD 
system that limit the amount of water that could be put to use. Actions necessary to remove all 
restrictions in the CCWD system and thereby allow CCWD to make full use of its contracted water 
supply woukj involve major improvements to the Contra Costa Canal system, which is owned by 
Redamatk>n. Compliance with all federal laws and regulations, ir>cluding NEPA and the federal 
Endangered Species Act, would therefore be required before such improvements could be made. 

The criteria that CCWD originally proposed to divert water into the Los Vaqueros Reservoir are 
described on pages 2-5 and 2-6 of the EIR/EIS under "Project Operations". The amount of surplus 
flow available is equal to the anKXjnt of water released from upstream reservoirs and floodflows 
in unregulated streams tf^t enter the Delta and are in excess of the amount of water needed to 
meet consumptive uses, export den^nds, and water quality starxlards. Typically, when surplus 
flows occur, they are very large and CCWD will not need to determine precisely how much surplus 
flow is available to ensure that only surplus flows are diverted. See also response to comment 
2-5 below. 

The analyses have eilso included 70-y6ar hydrology for: 1) D-1485 standards; 2) Draft D-1630 
standards; and 3) D-1485, with the current NMFS CVP-OCAP Biological Opinion on Winter-Run 



Response to Comments o( the U.S. Environmental Protection Agency 

5-37 



Salmon (February 12. 1993) and the FWS CVP-OCAP Biological Opinion on Delta smelt (May 26, 
1993). In these cases, surplus flows were those over and above the flows necessary to meet all 
the requirements of the standards and Biological Opinions, consumptive use in the Delta, and 
diversions by other projects. 

2-4. As described above in response to comment 2-2, CCWD recognizes that the existing Delta water 

quality standards will be revised. CCWD believes that It has conducted a reasonable analysis and 
also t>elieves that attempting to define possible future water quality standards is unnecessary for 
adequate impact assessment and would be speculative. 

See also the response to comment 2-2. CCWD has conducted a wide range of studies that 
included numerous potential water quality standards. 

2-5. As a result of comments received on the draft EIR/EIS and meetings with the various resource 

agencies, CCWD and Reclannation have developed rr>ltigation measures that not only reduce 
impacts to Delta resources, but actually Improve conditions as compared to no project, particularly 
for winter-run Chinook salmon. These measures consist of revisions to the Los Vaqueros Project 
operations in terms of the timing and magnitude of diversions from the Delta. Under the proposed 
mitigation plan, CCWD will use a portion of the water stored in the Los Vaqueros Reservoir in lieu 
of direct diversions from the Delta during the winter-run chinook salmon's season of highest 
vulnerat>ility. This operation will allow CCWD to eliminate all its diversions from the Delta, including 
those from its existing intake at Rock Slough, for a total of approximately 30 calendar days 
between March 15 and May 15 of each year. In addition, CCWD will generally not fill the Los 
Vaqueros Reservoir between March 15 and May 31. 

The revised project operations are fully described in the biological assessment for the proposed 
project as are the effects of the revised operations on special -status fish species. The mitigated 
opjerations are also described in Chapter 4 of the final Stage 2 EIR/EIS, along with a discussion 
of effects on other fish species. 

2-6. As described in the Stage 2 EIR/EIS and Appendix B to CCWD's Section 404(b)(1) alternatives 

analysis, CCWD expended considerable effort to facilitate other agencies' participation in the Los 
Vaqueros Project since 1985 Benefits to CCWD, other participants, and the environment could 
perhaps be realized from a joint-participation project. CCWD has encouraged and led discussions 
of regional water management issues and believes that efforts to solicit participation have been 
extended to all potentially interested parties at the expense of delaying the planning, study, and 
implementation of the proposed project. 

2-7. CCWD and Reclamatkjn included the Kellogg Reservoir as an alternative in the Stage 2 EIR/EIS. 

Although implementing the proposed project would not physically preclude developing the Kellogg 
Reservoir, CCWD is unatjie to furxJ such an additional project and will be unable to do so for the 
foreseeable future. In addition, CCWD and Reclamation are not aware of any other entity that has 
plans to propose construction of a second reservoir at this location. The Kellogg Reservoir 
Alternative would have to overcome numerous environmental regulatory issues. The reservoir site 
contains many acres of wetland habitat and numerous special-status plant species populations and 
provides habitat for the San Joaquin kit fox. Therefore, CCWD and Reclamation do not believe 
that developing the Kellogg Reservoir should be considered reasonably foreseeable. 

2-8. The Fdsom Dam and Reservoir operattons BIS was not available for analysis before the draft 

EIR/EIS was released. An examination of the operations studies for the proposed reoperation of 
Folsom Reservoir (Appendix K of the reoperation EIS) reveals that Delta outflow is likely to 
increase in November and December in a large percentage of years, while it is likely to decrease 
in February, March, April, and May. 



R«Sf>ons» to Comments ot the U.S. Environmental Protection Agency 

5-38 



The reoperation of Folsom Reservoir would tend to increase fall surplus flows and decrease winter 
and spring surplus flows. The reoperation of Folsom Reservoir would tend to reduce end-of-year 
storage in CVP reservoirs, thus increasing the risk of difficulty in meeting water quality standards. 
In addition, the operations studies show occasional drops In Delta outflow in late summer. These 
effects could translate into higher salinity at CCWD's intakes during some periods. This may result 
in a slight reduction of Los Vaqueros Project performance and an increase in salinity levels of 
water delivered to CCWD customers, and may have adverse impacts on municipal water supplies. 
However, the conclusions conceming the impacts of the l_os Vaqueros Project would not change. 

This would slightly increase the possibility of reservoir filling in November and December and 
decrease it in February through May. This would benefit Delta smelt, winter-mn Chinook salmon, 
and other fish species. 

2-9. Surplus flows are defined as flows in excess erf those needed to nrteet water supply demands and 

water quality ar)d flow requirements In the Sacramento Rh/er and San Joaquin River systems. 
CCWD, through water rights applicatbn 20245 filed In the early 1960s, has a higher priority to 
surplus Delta flows than other projects currently urxJer review. Therefore, the proposed diversions 
for the Los Vaqueros Project could conceivably impinge on the ability of other future projects to 
divert surplus flows. It should be noted, however, that nnany of the projects included in the 
cumulative future analysis do not depend entirely on surplus flows. Many of these projects would 
rely on water released from upstream storage reservoirs. In addition, because surplus flow is 
defined as the amount of water in excess of the amount needed to meet water quality and flow 
standards, changes in the water quality or flow standards that increase required flows would 
concurrently reduce the amount of surplus water available. Therefore, the Los Vaqueros Project, 
along with other proposed projects, could not impair the ability to meet future water quality 
starxJards. 

2-10. Comment noted. See response to comment 2-5. CCWD and Reclamation believe that the Los 
Vaqueros Project, with the operational mitigation measures developed as part of the biological 
assessnnent, would provide substantial benefits and significantly more flexibility to nnanage CCWD 
diverskjns to reduce or avokJ impacts on Delta fish species. 

2-11. Comment noted. See response to comment 2-5 and the biological assessment for fish species 
for the description of CCWD's mitigation that would restrict pumping during sensitive periods. 

2-12. Comment noted. If CCWD is not allowed to meet its full water demands, impacts of the Los 
Vaqueros Reservoir Alternative on the Delta would be similar to those described in the Stage 2 
EIR/EIS under "Existing Conditions" headings in Chapters 3, 4, and 5. CCWD and Reclamation 
believe that the Stage 2 EIR/EIS dearly separates the impacts of the project from effects of 
Increased water demands. The revised operational strategy that CCWD has developed as 
mrtigatksn for the proposed project indicates that impacts on some Delta resources would actually 
be reduced by Implementing the proposed project. 

2-13. CCWD has two water rights applicatk>ns pending ttefore the California State Water Resources 
Control Board for the Los Vaqueros Project. Application 20245 is for diversion into storage of up 
to 163,000 af/yr at the Los Vaqueros Resen/olr site or, alternatively, up to 135,000 af/yr at the 
Kellogg Reservoir site. Applicatkin 25516 is a partial assignment of a state filing for diversion from 
Kellogg Creek. Applicatton 25516 includes a storage component of 10.800 af/yr at the Los 
Vaqueros Reservoir site and 14,800 af/yr at the Kellogg Reservoir site. In addition, application 
25516 Includes a small direct diverskxi component from Kellogg Creek. 

Although CCWD had determined which alternatives would be addressed in its EIR/EIS for the Los 
Vaqueros Project, CCWD filed these water rights applicattons with the California State Water 
Resources Control Board before completing its extensive alternatives analysis and the draft Stage 



Response to Comments of the U.S. Environmental Protection Agency 

5-39 



2 EIR/EIS. The water rights application process provides the ability to reduce the quantities and 
rates o* water diversion but does not allow an application to be increased without refiling the 
application. 

To ensure that feasible alternatives were not eliminated and to minimize potential schedule delays 
caused by the need to refile an application if changes in the project occurred, CCWD intentionally 
filed applications for larger quantities o* water and greater rates of diversion than its projected 
need. The Stage 2 EIR/EIS, however, only analyzes and provides environmental documentation 
for attematives that are consistent with CCWD's identified water quality and reliability objectives. 

The water rights applications will be reduced to be consistent with CCWD's staff-preferred 
alternative identified in the Stage 2 EIR/EIS. Mal<ing the water rights applications consistent with 
CCWD's proposed action that was addressed in the Stage 2 EIR/EIS will involve reducing the 
quantity of water that can be diverted to storage to 100,000 af, reducing the diversion rate at the 
new supplemental intal<e from 600 cfs to 250 cfs, and eliminating the Kellogg Reservoir site from 
the water rights application. 

CCWD has not provided adequate environmental documentation under either CEQA or NEPA to 
construct or operate a project other than those that are considered in the Stage 2 EIR/EIS. In 
addition, CCWD's draft amended water service contract with Reclamation specifically states that 
"in utilizing its CVP water supply in conjunction with its Los Vaqueros water rights water, the 
District shall not deliver within its existing service area, in any one year, a quantity of water in 
excess of 195,000 acre-feet". 

Therefore, the total anrKwjnt of water available for use within CCWD's service area under both Los 
Vaqueros water rights and through CCWD's contract with Reclamation is 195,000 af. 

2-14. Comment noted. To reduce effects on Delta smelt, this mitigation measure would need to be 
comtnned with increased San Joaquin River inflow as descrit>ed on page 4-52 of the Stage 2 

EIR/EIS. 

2-15. Comment noted. 

2-16. See response to comment 2-5. 

2-17. See response to comment 2-5. It is important to note tfiat the normal operations of the Los 
Vaqueros Project would reduce diversions from Rocl< Slough by 50-80% during sensitive fish 
periods. Also, the mitigated operational scenario developed by CCWD and the resource agencies 
prioritizes diversions during the sensitive fish period. 

2-18. Comment noted. CCWD and Reclamation recognize the complexity of the water supply system 
and lii<ely effects thiat changes in water demands arxj water quality standards would have on Delta 
and upstream fisheries. Because of the numerous and complex factors that affect fish populations, 
the analysis in the Stage 2 EIR/EIS focused on changes In specific conditions at specific locations. 
Although CCWD and Redannation acl<nowledge that, under the future corxjitions scenario 
described in the Stage 2 EIR/EIS, temperature conditions for chinool< salnrKsn upstream in the 
Sacramento River may be detrimental, the proposed project has virtually no effect on upstream 
corxjitions. The proposed project does, however, reduce entrainment below levels that would 
occur without tf>e proposed project, regardless of the number of fish present. 

2-19. The Los Vaqueros Project will rely in part on surplus flows for filling the reservoir. Some surplus 
flow statistics from three DWRSIM analyses are given below. 



Response to Comments of th« U.S. Environmental Protection Agency 

5-40 



The statistics reveal that, typically, when surplus flows exist, the flows are very large. Thus, the 
addition of the new facilities would not significantly affect project performance. 

Increased demands would tend to reduce periods of snwUI surplus flows and increase periods of 
no surplus flows (compare DWRSIM analyses A7e and 543b or A7e and 476b). However, only a 
small difference exists between the future demand scenario and future buildout with Los Banos 
Grandes, Kem Water Bank and Delta chiannel enlargements (compare DWRSIM analyses 543b and 
476b). The future case was examined in detail. It is not expected that the slight change in surplus 
flow availability caused by the addition of the facilities mentioned will have a large effect on Los 
Vaqueros Project performance, eilthough it would certainly reduce Los Vaqueros Project flexibility 
and performance by a small amount. 



Percent of Months with Surplus Row 
under Various Scenarios (1922-1978) 

A7e 543b 476b 

No surplus 59.3 64.0 65.3 

1-12TAF/month 0.4 0.3 0.6 

12-20 TAF/month 0.3 0.0 0.1 

20-100 TAF/month 3.4 2.3 2.6 

> 100 TAF/month 36.7 33.3 31.4 

Maximum (MAF/month) 11.6 11.6 11.6 



Notes: TAF = thousand acre-feet. 

MAF = million acre-feet. 
A7e = existing conditions. 
543b = future demands, existing facilities. 
476b = future buildout demands, existing facilities plus Los Banos Grandes, Kern Water 

Bank, North and South Delta Management Plan. 
Los Vaqueros fNling capacity = 12 TAF/month. 

2-20. The effects of an isolated facility on Delta flows and the ability to deliver water to any of the 
alternate intake sites described in the Stage 2 EIR/EIS is entirely dependent on the design and 
locatkxi of such a facility. Because no plans for such a facility have been developed, estimating 
how water would be delivered to CCWD or what effects such a facility, or CCWD diversions with 
such a facility, could have on Delta resources would be speculative. 

2-21. CCWD and Reclamation antk;lpate that If irKX>nsistencies exist between operating the Los 
Vaqueros Project and attaining Delta water quality standards, Los Vaqueros Project or Central 
Valley Project operatkxis would be limited to ensure compliance with these future water quality 
standards. Although limitations on Los Vaqueros Project operations may reduce tfie percentage 
of time that CCWD water quality and reliabillry goals are achieved as compared to that described 
In the Stage 2 EIR/EIS, CCWD believes that the Los Vaqueros Project will provide a benefit in 
temfis of both water quality and reliability regardless of implementation of new Delta water quality 
starxlards. 

2-22. The kxatkxi of the intake would have rx) effect on r>et flows In tfie San Joaquin River near Antioch, 
nor on the calculation of QWEST. The current and proposed intakes are both in the same general 
area and draw water out of Old River (indirectly, in the case of the current location) and therefore 
have the same effect. 



Response to Comments of the U.S. Environmental Protection A^ncy 

5-41 



The supplemental intake Is expected to provide improved water quality compared to Rock Slough, 
but net flows in the lower San Joaquin would be the same regardless of which intake is used. 

2-23. Since puWication of the draft Stage 2 EIR/EIS and since the U.S. Environmental Protection 
Agency's letter was written, the California State Water Resources Control Board has changed its 
approach for setting water quality and flow standards. In order to be responsive to requests for 
additkDnal Information, CCWD has analyzed \he project for a variety of conditions, Including 70- 
year hydrology for: 1) D-1485 standards; 2) Draft D-1630 standards; and 3) D-1485, with the 
current NMFS CVP-OCAP Biological Opinion on Winter-Run Salmon (February 12, 1993) and the 
FWS CVP-OCAP Biological Opinion on Delta smelt (May 26, 1993). These cover a wide range of 
alternative standards (sumnnary results are presented in Attachment 2). 

2-24. Generally, the proposed project may result in a minor increase in upstream resen/oir storage, 
depending on Reclamation's operations. Although this Iricrease in storage alone is probably 
insufficient to affect temperatures upstream, the increase along with other similar increases could 
improve temperature corxjitions upstream. 

2-25. Comment noted. 

2-26. Comnr>ent noted. 

2-27. Comment noted. CCWD and Reclamation believe that a substantial increase in fish populations 
within the resen/oir is beneficial, regardless of whether these populations consist of exotic species. 
The Stage 2 EIR/EIS does not, however, compare these increased populations with detrimental 
effects on Delta fish populations. 

2-28. See response to comment 2-5. 

2-29. Comment noted. A detailed wetland mitigation plan has been prepared and is included as an 
appendix to the final Stage 2 EIR/EIS. 

2-30. As described in response to comment 2-3 above. The proposed project does not greatly increase 
CCWD's atMlity to divert water from the Delta. In addition, because the proposed project is 
intended to provide water quality and reliability Ijenefits to growth already planned within the 
existing CCWD sen/ice area, the proposed project would not alter the pattern, density, or location 
of growth in Contra Costa County and would therefore have no effect on air quality. 

2-31. See response to comment 2-30 above. The improvement of CCWD's system capacity under the 
No-Action Alternative would accommodate growth planned to occur within the CCWD service area. 
This growth is accounted for in the recently released dean air plan for the Bay Area. Therefore, 
growth accommodated by increased system capacity under the No-Action Alternative would be 
consistent with local air quality planning and would not cause additional air quality impacts. 

2-32. Thie effects o* the project alternatives on energy demand are extremely small (much less than 1 % 
of regional energy demand) and would not significantly affect energy production or related 
emissions. 

2-33. CCWD f«s already incorporated feasible measures, such as watering during construction, into the 
proposed project. These measures are descrit>ed in the Stage 2 EIR/EIS Technical RepxDrt. The 
imptact analysis in the Stage 2 EIR/EIS acknowledges that, even with tfiese measures, significant 
air quality impacts wHI occur during the construction period. 

2-34. Phasing construction of various project components was also considered, but phasing would not 
substantially reduce fugitive dust or ozone precursor emissions. Over 90% of these emissions 



Response to Comments of the U.S. Environmental Protection Agency 

5-42 



would result from constructing the dam and reservoir. The simultaneous contribution from the 
construction of other project components is minor. 

2-35. No feasible measures are available to reduce the number of trips during the construction period. 
Construction materials must be delivered from offsite and specific quantities of various materials 
are required to construct the proposed project. Although the number of trips per day could 
coTK^eivably be reduced, this would simply lengthen the constructbn period, causing increased 
emissions over a longer period and resulting in substantial costs to CCWD ratepayers. 

Mitigation measure 14-1, which is included in the environmental commitments list in the Stage 2 
EIR/EIS, would help reduce recreation-related trips to the watershed. 

2-36. If the proposed project is not approved, CCWD may sell the lands it has acquired. This possible 
outcome of the No-Action Alternative is described on page 2-3 of the Stage 2 EIR/EIS. 

2-37. Comment noted. Reclamation compliance with the Fish and Wildlife Coordination Act is included 
in Attachment 4. A Fish and Wiidlrfe Coordination Act report will also be solicited from USFWS 
by the Corps after the notice of availability of the final EIR/EIS is published and before any 
decision by the Corps on the Los Vaqueros Project. The biological opinions for San Joaquin kit 
fox, bald eagles, Delta smelt, and winter-run Chinook salmon are summarized in Chapter 20, 
"Consultation and Coordination". 

2-38. No relatk>nship exists between growth occurring in eastern Contra Costa County and the proposed 
project. In addition, the proposed project could not meet CCWD's water quality and reliability 
goals for an expanded sen/ice area because the sizing of proposed facilities, including the 
reservoir, would be inadequate. The primary reason for entering into these agreements is that the 
area is currently expanding, and existing water service providers are irrigation districts that are 
unable to provide municipal and industrial water service, even though they have adequate water 
supplies to serve the area. 

2-39. The Stage 1 EIR for the Los Vaqueros/Kellogg Project was prepared and certified by CCWD in 
1986. That EIR generally evaluated a variety of measures that CCWD could implement to improve 
the quality and reliability of its water supply. During the review process, 26 letters of comment 
were received and five people provided comments at public hearings for the project. Several 
comments focused on vegetation and wikjiife issues, while the remaining comments were specific 
to the interest of the commenters. 

The Vasco Road and Utility Relocation Project EIR is incorporated into the Stage 2 EIR/EIS by 
reference and is available for review from CCWD. Forty-two letters of comment were received and 
24 people provkJed comments at puWk: hearings for the EIR. Issues raised by commentors were 
generally focused on the effects of the project on transportation, vegetation and wildlife resources, 
quality of life, and mineral resources. 

2-40. Chapter 5 of the Sectkxi 404(b) (1 ) alternatives analysis, prepared by CCWD and incorporated into 
the Stage 2 EIR/EIS by reference, fully addresses the issue of reliability, including potential 
damage to £ill vulnerable CCWD facilities, such as the Contra Costa Canal intake facilities, and 
pumping plants and power facilities, and concludes that most CCWD and appurtenant facilities 
coukJ be damaged in a severe earthquake but would be operational again after a relatively short 
period. The controlling emergency for developing water reliability criteria is a multiple Delta levee 
failure, whk;h could last from 1 to 6 months. 

2-41. The wetland acreage numbers used in the wildlife chapter of the Stage 2 EIR/EIS refer to types 
of wetlands that provide specific wildlife values, while the acreage numbers used in the vegetation 
chapter refer to all areas that meet the criteria for wetlands even though they may not provkJe 
substantial wildlife values. 



Response to Comments of the U.S. EnvironmentaJ Protection Agency 

5-43 



MPY-13-1992 06:39 FROM NOhih ECOL. SCCNSERUhtTION 



TO 







LETTER NO. 3 



OffK>B of the CWwf Scientist 

Was^>1ngcon, D C 20230 _ 

May 12, 1992 I 



C^ 






Mr . John S . Gx'egg 
Assistant General Manager 
Contra Costa Water District 
P.O. Box 4121 

Concord, California 94524 
Dear Mr. Gregg: 

Enclosed are coaanents on the Draft Env<r-r,r,™^«^*i t 

for LOB Vaqueros Project, c^a^^fcofJaco^lf^^'f^ff^if^^S^^^t 
hope our comments will assist vou Th^nV^I^'* ^ ^^*- ^^ 
opportunity to review tSe dSu^eni. ^°'" ^""^ ^"^^"^ "^ ^" 

Sincerely, 



'V/UulMkim 



Enclosure 



David cottingnam 

Director 

Ecology and Conservation Office 



DECEIVED 
MAY 1 2 1992 



5-44 






I' 



^^^^^ 



"^mw 



MfiY-13-1992 08:39 FROn NOfiH ECOL . 8,C0NSERU(hT 1 ON TO 85107981452 P. 03 



KATIOMAL OCEAKXC AND ATMOSPHERIC ADmHI STRATI ON 

C010CZMT8 ON LOS VAQUSR08 PROJECT 
CONTRA COSTA COUNTY/ CALI70RHIA 

The National Marine Fisheries Service (NMFS) , Southwest Region, 
has reviewed the svibject docxunent and offers the following 
coioments. If you have questions concerning these comaents or 
wish to discuss the project further, please contact Michael 
Thabault, 777 Sonoma Avenue, Room 325, Santa Rosa, California 
95404, telephone (707)578-7513, or the Protected Species 
Division, Janes Lecky, 501 West Ocean Boulevard, Suite 4200, Long 
Beach, California 90802-4213, telephone (310)980-4015. 

The National Marine Fisheries Service is responsible for 
preserving and enhancing marine, estuarine, and anadromous fish 
resources and the habitats that support these resources. The 
Sacramento and San Joaquin Rivers, as well as the Delta, support 
many species of anadromous and estuarine fish. These include 
American shad, striped bass, sturgeon, steelhead trout, and 
Chinook salmon, including the protected winter-run Chinook 
salmon. Winter-run Chinook salmon is listed as Threatened under 
the Federal Endangered Species Act (FR 55, No. 214, 46515). 
Several of these species have vmdergone significant declines in 
recent years. 

General Coanents 

CCWD cxirrently has a water right entitlement from the U.S. Bureau 
of Reclamation for 195,000 acre feet (AF) of water, of which they 
can deliver between 120,000-130,000 AF. Although the projected 
demand at full build out in a critical year is 205,000 AF, 
conservation and reclamation reduce that demand to 188,000 AF. 
All analyses in the DEIS/DEIR are predicated on delivery of neeur 
full entitlement. 

3-1 
We understand that CCWD has applied for an additional water 

entitlement from the state Water Project (SWP) for 163,000 AF for 

the Los Vaqueros Project (sized at 150,000 AF not 100,000 AF as 

reported in the DEIS/DEIR) . CCWD also plans to build an 

additional reservoir (Kellogg Reservoir) and are applying for an 

additional 135,000 AF of State water. These actions should be 

identified and discussed in the document. 



1, 

5-45 



MftY-13-1992 08=40 FROM NOAA ECOL . E-COt^SEPUfiTION 



TO 



85107981452 P.OJ 



I 
i 



3-2 



3-3 



CCWD prefers 90 days of emerqency storage. However, only 30-day 
storage can be built at this time. If the CCWD plans on fully 
utilizing the additional entitlement, it should be discussed in 
the EIS. A f\irther consideration is that water rights are 
aaintained through usage. It should be indicated whether CCWD 
plans to re-sell that water or intends for the State to 
reallocate the water elsewhere xmtil CCWD has the capacity to use 
it. Any of these options will result in substantially nore water 
exports than described in the DEIS/DEIR. 

The State of California is now involved in water quality hearings 
to address the needs of fish and wildlife in the San Francisco 
Bay and Delta. The present Decision-1485 Standards are not 
adequately protecting fish and wildlife resources within this 
complex estuarine system. We believe that this Los Vaqueros 
Project, as well as many other projects involving increased 
exports from the Delta, are premature. It is anticipated that 
the State, at the insistence of EPA, will establish stricter 
water quality standards for the Bay/Delta. These standards will 
affect all new water management decisions, including this 
project's viability and the new water rights being sought. This 
possibility needs to be addressed. 

g pecifio comaents 

The Effected Environment Section for fisheries. Chapter 4, 
discusses the qualitative status of fisheries. However, there is 
no quantitative discussion of the impacts from existing CCWD 
facilities, NMFS maintains that environmental conditions in the 
Sacramento/ San Joaquin Delta (Delta) are cxirrently unacceptable. 
CCWD is contributing to these conditions. The existing intake on 
Rock Slough is presently unscreened. A discussion of direct 
losses of fish associated with this facility should be in the 
DEIS/DEIR. Without an appropriate baseline of information, 
decisions on impacts and mitigation cannot be made. The 
quantitative data supplied are derived from model projections. 
Although xBodelling is a useful tool, field data are needed to 
verify a model's conclusions. 

The DEIS/DEIR discusses the significant impacts of existing 
facilities on fisheries. We realize that when comparing this 
project with the much larger State Water Project (SWP) emd the ^-S 
Central Valley Project (CVP) , CCWD exports are considerably less. 
However, because their proposal is smaller, they state that their 
impacts will not be significant. We do not agree with this 
conclusions. 

All analyses presented use the 1922-1978 hydrologic record, yet [ 
hydrologic records are now available through 1991. Using current ! 
information will be much more representative of existing 3-6 

conditions. Such information would reflect the higher rates of 
diversions that have occurred since 1978 and the continuing 



3-4 



5-46 



MfiY-13-1992 08:41 FROM NOftA ECOL . S.CONSEPUhlT I ON TO 85107981452 P. 05 



drought conditions. Additionally, to fully evaluate inpacts to 
fisheries, an analysis should use the standard five water-year 
types. This will aid CCWD in analyzing operational alternatives 
to avoid or ninimize annual impacts. 

The Fisheries Iiapact Assessment Methodology discussed in Appendix 

B is identical to that presented in the Delta Wetlands Project 

DEIS/DEIR and the Arvin-Edison/Metropolitan Water Exchange 

Program DEIS/DEIR. The Los Vaqueros DEIS/DEIR should discuss how 3.7 

this methodology directly applies to the Los Vaqueros Project. 

Assumptions should be included that consider operations during 

all water-year types, using the expanded hydrologic record. 

Mitigation measures are not adequately described. The major 
mitigation component identified is participation in the Two 
Agency Agreement negotiations. CCWD would contribute funding to 
ongoing habitat improvement projects identified through the Two 
Agency Agreement. The Two Agency Agreement was established to 
mitigate for past and present impacts caused by the swp and CVP 
facilities and operations. Much of the mitigation described in 
this document is either being implemented or considered as 
mitigation for SWP/CVP facilities. Furthermore, the period for 3-8 
completing the Two Agency negotiations is not established, 
rendering the mitigation to be of questionable value for the Los 
Vaqueros Project. These negotiations may not provide adequate 
mitigation in the long-term, and may not mitigate for impacts to 
all species. The focus of the Agreement is on striped bass, 
salmon, and steelhead; there are other resident species not 
considered. Participation in, or funding of an agreement with 
unspecified mitigation cannot be considered adequate for this 
project. 

The CCWD presently causes unquantified impacts to fisheries at 
the water intake located on Rock Slough. If that facility 
remains unscreened, fxirther mitigation may be required. Some 
individual aspects of the mitigation do not compensate for the 
impacts described. Habitat restoration, although commendable, 
does not mitigate for direct or indirect losses of fish. 
Furthermore, habitat improvement outside the Delta may not 
adequately mitigate for losses of valuable Delta habitat. Also, 
without adequate freshwater flows and other fish protective 
measures, habitat enhancement may not be the most appropriate 
mitigation measure. Without a more specific plan, we cannot 
adequately evaluate the proposed mitigation. Hatcheries may be 
useful in mitigating for director indirect losses to population. 
However, they are not considered by NMFS as appropriate 
compensation for habitat losses and may not be appropriate for 
fish losses (e.g., winter-mn Chinook salmon). The DEIS/DEIR 
should identify realistic mitigation measures that can be readily 
implemented to offset all unavoidable impacts. These may 



5-47 



3-9 



riAY-13-1992 08=42 FROM NOfiA ECOL. &C0N5ERUHTI0tJ 



TO 



85107981452 P. 06 



i 



include, but not be limited to, changes in operations to avoid 
peak juvenile fish occurrences in the Delta or participation in 
Delta-wide protective fish screening programs. 

Many mitigation measures outlined in the DEIS/DEIR are 
inappropriate to offset impacts to winter-run chinook salmon. 
Although Federal consultation under S7 of the Endangered Species 
Act has not yet been initiated by the U.S. Bureau of Reclamation, 
there have been discussions with them concerning the 
consultation. Comments concerning this project proposal, 
relating to winter-run, will be provided when the Biological 
Assessment is received by the Protected Species Division in Long 
Beach, California. The CCWD must be aware that, although 
avoiding and minimizing impacts to winter-run may accomplish a 
Non-Jeopardy Opinion for that species, it may not adequately 
address impacts to other fish species. 



3-10i 



5-48 



Responses to Comments of the National Marine Fisheries Service 



3-1. CCWD has two water rights applications pending before the California State Water Resources 

Control Board for the Los Vaqueros Project. Application 20245 is for diversion into storage of up 
to 163,000 af/yr at the Los Vaqueros Reservoir site or, alternatively, up to 135,000 af/yr at the 
Kellogg Reservoir site. Application 25516 is a partial assignment of a state filing for diversion from 
Kellogg Creek. Application 25516 includes a storage component of 10,800 af/yr at the Los 
Vaqueros Reseivoir site and 14,800 af/yr at the Kellogg Reservoir site. In addition, application 
25516 includes a small direct diversion component from Kellogg Creek. 

Although CCWD had detemiined which altematives would be addressed in its EIR/EIS for the Los 
Vaqueros Project, CCWD filed these water rights applications with the California State Water 
Resources Control Board before completing its extensive altematives analysis and the draft Stage 
2 EIR/EIS. The water rights applteation process provides the ability to reduce the quantities and 
rates of water diversion, but does not allow an applicatkjn to be increased without refiling the 
application. 

To ensure that feasible alternatives were not eliminated and to minimize potential schedule delays 
caused by the need to refile an application if changes in the project occurred, CCWD intentionally 
filed applications for larger quantities of water and greater rates of diversion than its projected 
need. The Stage 2 EIR/EIS. however, only analyzes, and provides environmental documentation 
for altematives that are consistent with CCWD's identified water quality and reliability objectives. 

The water rights applications will be reduced to be consistent with CCWD's staff-preferred 
altemative identified in the Stage 2 EIR/EIS. Making the water rights applications consistent with 
CCWD's proposed action that was addressed in the Stage 2 EIR/EIS will involve reducing the 
quantity of water that can be diverted to storage to 100,000 af, reducing the diversion rate at the 
new supplemental intake from 600 cfs to 250 cfs, and eliminating the Kellogg Reservoir site from 
the water rights application. 

CCWD has not provided adequate environmental docunrwntation under either CEQA or NEPA to 
construct or operate a project other than that considered in the Stage 2 EIR/EIS. In addition, 
CCWD's draft amended water service contract with Redamatton specifically states that "in utilizing 
its CVP water supply in conjunction with its Los Vaqueros water rights water, the District shall not 
deliver within its existing service area, in any one year, a quantity of water in excess of 195,000 
acre-feet." 

Therefore, the total amount of water available for use within CCWD's service area under both Los 
Vaqueros water rights and through CCWD's contract with Reclamation is 195,000 af. 

3-2. CCWD's emergency storage goals vary depending on the type of year. As stated on page 1-5 

under "Primary Objectives", one of CCWD's three primary objectives Is to improve the reliability 
of the CCWD supply by providing emergency storage to supply 75% of the maximum projected 
3-month demand in 2025 (56,000 aO. with the provision that up to 26.000 af of this emergency 
storage can be used to enhance water quality during dry and crttkal years. 

The proposed Los Vaqueros Reservoir Project achieves this objective. CCWD has no plans and 
no Identified funding sources to constmct additkinal storage and. as described in the response 
to comment 3-1 above, will modify its water rights application to confomn to the project descrit)ed 
in the Stage 2 EIR/EIS as modified by the biological assessment for fish species. 



Response to Comments of the National Marine Fisheries Service 

5-49 



3-3. CCWD and Reclamation recognize that new water quality standards will be set in the Delta. The 

state Is obligated to review such water quality standards every 3 years. CCWD and Reclamation 
continue to believe that rt is appropriate to proceed with tlie Los Vaqueros Project at this time. 

In order to be responsive to requests for additional information and to assess the project with 
potential water quality standards, CCWD has analyzed the project for a variety of conditions, 
induding 70-year hydrology for: 1) D-1485 standards; 2) Draft D-1630 standards; and 3) D-1485, 
with the cun-ent NMFS CVP-OCAP Biological Opinton on Winter-Run Salmon (February 12, 1993) 
and the F=WS CVP-OCAP Biological Opinion on Delta smelt (May 26, 1993). These cover a wide 
range of alternative standards (sumnnary results are presented in Attachment 2). The analyses 
show that while project performance changes slightly, project Impacts are the same or are less 
under the more restrictive standards. 

CCWD currently fias almost no storage in its water distritxjtion system. If a levee failure or other 
event occurred that rendered CCWD's Rock Slough Intake unusable, CCWD could meet its 
demands for only several days. This emergency supply need is unrelated to existing or future 
Delta water quality standards. 

As a Central Valley Project contractor and holder of state water rights. CCWD would be subject 
to all appropriate restrictions placed on Delta diversions as a result of state water right 
proceedings and compjliance with other state and federal laws and regulations. The Los Vaqueros 
Project would greatly increase CCWD's operational flexibility and could be a valuable addition to 
the Delta water system b)ecause It could allow CCWD to modify its operations to avoid or reduce 
impacts on sensitive Delta resources. 

It is also important to note that the Los Vaqueros Project does not greatly increase the ability of 
CCWD to divert water from the Delta. Although the Los Vaqueros Resenyoir would eliminate the 
need to make improvements to portions of CCWD's Contra Costa Canal system, other major 
restrictkjns would still exist in the CCWD system that limit the amount of water that could be put 
to use. Actions necessary to remove all restrictions in the CCWD system and thereby allow CCWD 
to make full use of its contracted water supply would involve major improvements to the Contra 
Costa Canal system, which is owned by Reclamation. Compliance with all federal laws and 
regulations, including NEPA and the federal Endangered Species Act, would therefore be required 
before such improvements coukJ be made. 

3-4. Direct losses attributable to CCWD's diversions are presented in the biological assessment for the 

proposed project. A biological assessment for fish species affected by the Los Vaqueros Project 
was submitted to the National Marine Fisheries Service on August 25, 1992 after several meetings 
to darify fishery issues. The biological assessment presents quantitative information regarding the 
current effects of CCWD operatkxis on Delta fishery condittons. This information is incorporated 
into the final EIR/EIS as appropriate. The biological opinion from NMFS is summarized in Chapter 
20, "Consultation and Coordination". 

3-5. CCWD and Redamation recognize that the Delta fishery is being affected substantially by existing 

water project operations. The Stage 2 EIR/EIS makes a distinction between direct impacts of the 
Los Vaqueros Project on Delta system fisheries and cumulative impacts, to which the Stage 2 
EIR/EIS acknowledges that CCWD is contributing, although in a very minor amount. The Stage 
2 EIR/EIS does, in fact, identify nunDerous impacts on Delta fisheries as contributing in a minor 
way to significant cumulative impacts (See pages 4-25 and 4-26 for example). CCWD and 
Redamatton recognize and state in Chapter 4 o* the Stage 2 EIR/EIS, "Delta System Fisheries', 
that, while project-related diversions are small compared to total Delta diversions, CCWD's 
incremental additions to the cumulative impact of all Delta diversions on fish populations are 
significant. See also response to comment 3-4 above. 



Response (o Comments of the National Marine Fisheries Service 

5-50 



3-6. The hydrologic analyses conducted for the Stage 2 EIR/EIS do not simulate actual flows that 

occurred historically in the Delta and upstreann rivers. Instead, these models use the existing or 
projected water supply system, existing or projected demands for water, and the estimated 
hydrology of the 1922-1978 hydrologic record to simulate how the Central Valley Project and the 
State Water Project systems would operate under various scenarios. Therefore, adding the 
hydrology of the 1979-1991 period does not significantly alter the results represented in the 
operations modeling conducted for the Los Vaqueros Project. 

Since the letter from the National Marine Fisheries Service was sent, operations studies for the 
period of 1922-1991 have become available. CCWD has analyzed the project for a wide range of 
conditions for 70-year hydrology, including: 1) D-1485 standards; 2) Draft D-1630 standards; and 
3) D-1485, with the cun'ent NMFS CVP-OCAP Biological Opinion on Winter-Run Salmon (February 
12, 1993) and the FWS CVP-OCAP Biological Opinion on Delta snnelt (May 26, 1993). Results are 
summarized in Attachment 2; the studies show either no change or reduced impacts. 

CCWD believes that analyzing fisheries impacts by the standard five water-year types would not 
provide substantial information. A brief analysis erf fishery impacts by water-year was presented 
in the biological assessment for this project. Assessing impacts by water-year type is not 
particularly useful because water project operations are not restricted by year type in any 1 year. 
For example, a critical year following a series of wet years nnay not result in substantial reductions 
in flow or effects on fisheries because water stored in reservoirs in previous years can be used to 
nrwike up for deficiencies that occur in any 1 year. Similarly, a wet year following several dry years 
may result in substantially more effects because much of the flow in that wet year is captured by 
reservoirs with increased capacity because of the previous dry years. Because no real pattem of 
year types exist, analyzing fishery impacts by year types provides little insight into a project's 
expected impacts on fisheries. 

3-7. The methodologies for the three referenced projects are essentially identical because they 
measure the same parameters (sun/ival of various fish species) at essentially the same locations 
(the Delta and upstream rivers and reservoirs) using the same input information (Delta inflow, Delta 
outflow. Delta export, and flow within Delta channels). The methodologies, therefore, could not 
be substantially different. See also responses to comments 3-5 and 3-6, above. 

3-8. As a result of comments received on the draft EIR/EIS and meetings with the various resource 
agencies, CCWD and Reclamation have developed mitigation measures that not only reduce 
impacts to Delta resources, but actually improve conditions as compared to no project. These 
measures consist of revisions to the proposed project operations in terms of the timing and 
magnitude of diversions from the Delta. Under the proposed mitigation plan, CCWD will use a 
portion of the water stored in the Los Vaqueros Resen/oir in lieu of direct diversions from the Delta 
durir^ the winter-run chinool< salmon's season of highest vulnerability. This operation will eillow 
CCWD to eliminate all its diversions from the Delta, including those from its existing intal<e at Rocl< 
Slough, for a total of approximately 30 calendar days between March 15 and May 15 of each year. 
In addition, CCWD will generally not fill the Los Vaqueros Reservoir between March 15 and 
May 31. 

The revised project operations are fully described in the biological assessment for the proposed 
project as are the effects of the revised operations on special-status fish species. The mitigated 
operations are also described In Chapter 4 of the final Stage 2 EIR/EIS, along with a discussion 
of effects on other fish species. The biologiC£tl opinion is summarized In Chapter 20, 'Consultation 
and Coordination*. 

3-9. See responses to comments 3-4 and 3-8 above. 



Response to Comments of tt>e National Marine Fisheries Sen/ice , 

5-51 



3-10. Comment noted. See responses to comments 3-4 and 3-8 above. CCWD and Reclamation 
believe that the Los Vaqueros Project will provide substantial operational flexibility and will allow 
better opportunities to minimize effects on other fish species. bm 

m 






Response to Comments of tt)e National Marine Fisheries Sen/ice 

5-52 







cCAJ/fo9'/ LETTER NO. 4 

'^ ^^ DEPARTMENT OF THE ARMY 

U.S. ARMY ENGINEER DISTRICT, SACRAMENTO . - — o ( 

CORPS OF ENGINEERS CLC- -^ •-> ^^ 

1325 J STREET -j' \\ 

SACRAMENTO, CALIFORNIA 95814-2922 ^ 

REPLY TO W-0 

ATTEKTIOM OF \ "> \J? 

June 3, 1991 (OHI^ 
Regulatory Section (199000070) 



Mr. James West 
Bureau of Reclamation 
2800 Cottage Way (MP-750) 
Sacramento, California 95825-1898 

Dear Mr. West: 

Enclosed are comments concerning our review of the 
cultural resources section of the draft Environmental Impact 
Statement (EIS) associated with the Los Vaqueros Project proposed 
by Contra Costa Water District. 

In addition, eligibility determinations and effect 
determinations must be completed and concurrence of the State 
Historic Preservation Officer (SHPO) obtained prior to 
finalization of the EIS. The results of these determinations and 
consultation with the SHPO should be discussed in the final EIS. 
Our understanding is that you have transmitted the eligibility 
and effect determinations to the SHPO for review and comment. 

For regulatory EISs, we require the draft eligibility and 
effect determinations be completed and the results discussed in 
the draft EIS. The draft EIS for the Los Vaqueros project does 
not meet the needs of our agency. However, we believe that as a 
result of your prompt attention to this matter, this 
deficiency is being resolved. . 

If you have questions concerning cultural resources please 
contact Ms. Patti Johnson, Corps archaeologist, at (916) 
557-6611. Questions concerning the associated Department of Army 
permits should be addressed to Ms. Jean Elder in our Regulatory 
Section at (916) 557-5256, 

Sincerely, 



Art Champ 

Chief, Regulatory Section 



Copies Furnished: 






Ms. Dana McGowan, Jones & Stokes Associates, Inc., 2600 V Street, 
Suite 100, Sacramento, California 95818-1914 
7'Mr. Gary Darling, Los Vaqueros Project, Contra Costa Water 
District, P.O. Box 4121, Concord, California 94524 

5^3 RECEIVED 

JUN 8 1992 



May 1, 1992 



Comments on "Los Vaqueros Draft Stage 2 Environmental Impact 
Report/Environmental Impact Statement for the Los Vaqueros 
Project", February 1992. 



1. All such statements in this document such as "Until these 
sites are evaluated for their NFIHP eligibility, all sites are 
assumed to be potentially eligible and any impacts on these sites 
would be significant" need to be revised in light of the current 
approach to the eligibility issue. The State Historic 
Preservation Officer's comments on eligibility and effects must 
also be included in this report as discussed previously in 
several meetings . 

2. In a number of instances the mitigation measures offered are 
reputed to "ensure protection" of the cultural sites and thus 
there supposedly would be no impacts to the sites. It is 
erroneous to assume this, since mitigation measures for cultural 
resources cannot "ensure" that the sites will be preserved or 
protected. Implementation of mitigation measures results in 
relative, not absolute, security for the sites. There is ample 
data nationwide as to the effectiveness of the various kinds of 
mitigation. The following statements from the report demonstrate 
this point. 

a. Page 11-21. "Fencing and monitoring to ensure that 
sites are protected might also be necessary and are described 
below." This is unclear. If fencing a site is meant, that is a 
known invitation to vandals. The site then becomes an 
"attractive nuisance" and promotes trespassing. If fencing a 
field or other large area is meant, then it should be realized 
that is not considered a deterrent. Please clarify and rethink 
this . 

b. Page 11-23. "Impacts on some sites from increased 
access and vandalism can be prevented by implementing a cultural 
resources management plan. The plan would include restrictions 
for use in areas of sensitivity (e.g., restrict use near NRHP- 
eligible properties and provide a monitoring program to ensure 
that NRHP-eligible properties are protected) . " Restricting 
access and monitoring may reduce the probability of impacts — that 
all depends on how restricting access and monitoring are actually 
accomplished — but these measures certainly do not ensure 
protection. 

c. Page 11-23. "To ensure the long-term protection of 
these sites, the plan would provide guidelines to prevent impacts 
on cultural resources^ such as restrictions for use in areas of 

5-54 



4-1 



4-2 



I 

n 



sensitivity, a long-term monitoring program to ensure that NRHP- 
eligible properties are protected in the future." This is the 
same az paragraph b. above and the same comment applies. Impacts 
are not going to be prevented , such measures are redoing the 
probability of damage. 

There are a number of other instances in this report where 
mitigation measures are discussed in this manner. It is 
misleading to the decision-makers who will assume that all that 
is required is implementation of these measures and the problems 
are solved. Mitigation measures should be viewed as risk 
reduction not risk elimination. The latter is an impossibility 
in most cases. This report needs to be rewritten in all 
instances where mitigation is discussed to reflect what actually 
can be accomplished, not some ideal that will not be reached. 

3. Page 11-6, Study Findings. There is at this time an Area of 
Potential Effect (APE) for this project. Using the word 
"tentative" APE suggests that there is a great deal of fluidity 
to the APE. It should be understood that virtually all projects ^^ 
undergo change to various features. It is suggested that 
"tentative" be eliminated, assume a given APE and identify it. 
Changes to the APE can, be addressed by stating that such 
revisions will be subjected to review by the SHPO along with 
identification of the cultural sites affected. 

4. Page 11-8, Impact Mechanisms. Revise "The alternatives 
considered in this EIR/EIS could affect historic, archeological, 
architectural, or traditional cultural properties eligible for 
the NRHP" to ... will affect.... Based on the current approach 
to the eligibility issue, it is most certain that the 
alternatives will indeed affect historic properties. It is not a 
possibility — affects will occur. The use of the word "could" is 
appropriate where impacts or mitigation measures to specific 
sites may not be known at this time. The decision-makers reading 
this report need to understand that impacts of some type are a 
certainty. 

5. Page 11-9, Reservoir Operation. Revise "Fluctuating ^"^ 
reservoir levels and the amount of water released into Kellogg 
Creek could affect historic properties near the reservoir high- 
water mark and downstream of the dam. Fluctuating water levels 
and hydrodynamic action could erode and degrade historic 
properties located at the water's edge". Again, fluctuating 
reservoir levels are known, virtually without exception, to erode 
sites. What is the point of referring to this as a possibility 
when it is indeed a certainty. Fluctuating water levels are 
perhaps the most damaging of impacts other than destruction by 
construction. The "could" in these two instances should be 
changed to "would". The "could" in "Land Management: Grazing 
Practices, .. .Fire, .. .Dryland Farming...." etc. is appropriate 
since there are options to impacting the sites. 



6. Page 11-9. Should there not be a "Land Use: Mitigation 

5-55 



4-5 



i 



Lands" section, since there will probably be mitigation lands 
other than the watershed lands? 

t 

7. Page 11-11, Purchase of Lands. "Limited access to, and a 
protection program for, the caves also will protect the 
archeological values present." See comment 2 above. Limited 
access to, and a protection program for the caves will reduce the 
risk of vandalism. It will not eliminate it. 

8. Page 11-21. Use the proper and legal term "State Historic 
Preservation Officer". The only time Office of Historic 
Preservation (OHP) is appropriate is when the actual agency is 
being referenced such as in Table 20-1. 

9. Page 11-21, Assess APE for Sensitivity of Buried 

Resources "if buried sites are found, they will need to be 

considered as part of the Section 106 review process." This 
sentence needs to be revised to something like "If buried sites 
are found, they will need to be evaluated for eligibility to the 
National Register of Historic Places and appropriate treatment 
developed in accordance with the Section 106 consultation 
process . " 

10. Page 11-21, Design Project Facilities to Be Unobtrusive 
Revise the paragraph to read: "...the facility should be 
designed to be architecturally compatible with historic 
properties and should be designed to blend visually with the 
surrounding area. Where appropriate, landscaping should be used 
to screen facilities from historic properties and to avoid or 
reduce visual impacts. The design of such facilities and 
landscaping would be undertaken in consultation with the SHPO. " 

11. Page 11-22, Site Evaluation and Data Recovery Measures 
Rewrite this paragraph with current approach as the basis for 
discussion. 

12. Page 11-23, Impacts on Cultural Resources from Long-Term 
Management Practices. Rewrite these two paragraphs from the 
point of view of risk reduction as discussed in comment 2 above . 

13. Page 11-24. Potential Impacts on Cultural Resources within 
Unsurveyed Portions of the Project Area. Revise last sJnte^ce in 
paragraph similarly to comment 9 above. The phraseolo^ is 
me^? appears as a "short-hand" version of what is really 



4-6 



4-7 



4-8 



4-9 



4-10 



4-11 



4-12 



14. Page 18-11. Environmental Consequences. Cultural 

TplT^r^^A^-^^''^^'^^^^ ^^^^^°" i^ ^°° ^^i^f- in accordance with 
CEQA guidelines and NEPA regulations as cited on page 18-1 nlst 

Tt ?;^r"^.^^ "".l^^ ^" reasonably foreseeable futSre actio^s^ 
should be Identified. The level of analysis for cultural 
resources is not consistent with that of other resource analvses 

Idintifn '°"^ ""^r"^^ °' quantification. For example, why'^not 
Identify how many known sites are in east county and the 

5-56' 



4-13 






percentage of these that have been destroyed by development 
Discuss how this project compares to that level of destruction 
(or preservation, as the case may be). 

r^^r,^!^^"'""'^' ^^^ -^^^^ sentence of the paragraph is an erroneous 
conclusion Preserving sites in one area does not compensate for 
the loss of sites in another. There is obviously as assumption 
that archeological sites are alike, therefore, if some are 
preserved in one location, then it is acceptable to destroy 
others m the project area. Please note that each archeological 
site is unique m some manner and provides data different than 
any other. If this were not the case, test excavation and data 
recovery would hardly be necessary. It should also be noted that 
data recovery as such does not entirely compensate for the loss 
of a site since the samples recovered are usually so small and 
the rest of the site may be completely destroyed. 

It should be remembered that preservation, not mitigation 
IS the preferred alternative as directed by Federal law This 
cumulative impact summary, as well as other statements in the 
document regarding mitigation appear to be complying with the 
process only without any real understanding of what will actually 
happen to the sites. ^That approach does not constitute a full 
disclosure as required for an EIR/eiS. 

i=;^ ^^?? ^°"^^- ^?^"^y Authority. The SHPO has more functions, 

especially since this is an EIS as well as an EIR, than simply 

commenting on eligibility. Also the National Historic 

Preservation Act as referenced in this table actually cites the 4-14 

Advisory Council on Historic Preservation (ACHP) , who is a party 

in the Section 106 consultation process. The ACHP should also be 

mentioned . 



5-57 



Response to Comments of the U.S. Army Corps of Engineers 



4-1. Chapter 11 of the final EIR/EIS contains a description of activities conducted in compliance with 

Section 106 of the National Historic Preservation Act since put)lication of the draft EIR/EiS. 
Attachment 3 to the final EIR/EIS indudes a letter from the State Historic Preservation Officer 
expressing concurrence with these findings. 

CCWD, Redamation, the US. Army Corps of Engineers, the California State Water Resources 
Control Board, and the State Historic Presen/ation Officer have developed and executed a 
programmatic memorandum of agreement that will determine how mitigation will be conducted 
for properties eligible for listing in the National Register of Historic Places. The agreement is also 
included in Attachment 3. 

4-2. The Intent of the mitigation measures is to reduce the impacts caused by the proposed action to 

a less-than-significant level. CCWD and Reclamation recognize that these measures will not 
ensure protection from all possible non-project-related Impacts, but believe that the measures 
descrit>ed in the EIR/EIS are appropriate and will reduce impacts to less-than-significant levels. 

For example, the fencing measure discussed in the EIR/EIS on page 1 1-21 is specifically aimed 
at preventing incidental impacts from construction activities and would be a short-term measure 
that would allow construction monitors to clearly delineate to construction crews areas to avoid. 
CCWD and Reclamation recognize that approval of the basis on which the Los Vaqueros Project 
will comply with Section 106 is necessary before receiving permits from certain state and federal 
agencies and has proceeded with studies based on that l<nowiedge. The process is described 
on page 11-21. 

4-3. At the time the draft EIR/EIS was published, an area of potential effect (APE) had not yet been 

firmly established. Since publication of the draft EIR/EIS, substantial progress has been made in 
complying with Section 106. This progress is discussed in Chapter 11 of the final EIR/EIS. 

4-4. The section discussed in this comment was written to generally describe potential impact 

mechanisms, not to descrilae impacts. Impacts of the project alternatives on historic properties 
are described under "Environmental Consequences" in Chapter 1 1 of the EIR/EIS. Impacts of 
reservoir operation on historic properties are described on page 11-11. 

4-5. Comment noted. The final EIR/EIS has been modified to reflect this change. 

4-6. See response to comment 4-2. above. 

4-7. Comnr»ent noted. All references to "OHP" have been changed to "SHPO" in the final EIR/EIS. 

4-8. Comment noted. The possibility of buried sites and the steps necessary to comply with Sec- 

tion 106 wUI be included in the cultural resources management plan and construction monitoring 
plan. Appropriate changes have been irx^luded in the final EIR/EIS. 

4-9. Comment noted. The final EIR/EIS has been modified to reflect this change. 

4-10. Substantial progress has been made in complying with Sectbn 106 since publication of tlie draft 
EIR/EIS. This progress is discussed In Chapter 1 1 of the final EIR/EIS. 

4-11. See response to comment 4-2, above. 



Response to Comments of the U.S. Army Corps of Engineers 

5-58 



4-12. Comment noted. The final EIR/EIS has been modified to reflect this change. 

4-13. CCWD and Reclamation believe that the cumulative impact analysis is appropriate. Mitigation 
measures proposed for the Los Vaqueros Project would fully compensate for the loss of cultural 
resources attributable to the proposed project and Implementation of the programmatic 
memorandum of agreement wiil result in no adverse effect to cultural resources. Therefore, the 
Los Vaqueros Project would not contribute to significant cumulative impacts. 

4-14. Comment noted. The final EIR/EIS has been rrxxjified to reflect this change. 



Response to Comments of the U.S. Amy Corps of Engineers 



5-59 



STATE OF CALIFORNIA 



Cc M \-73M \ u*^ \3. :i.^.5- 



LETTER NO. 5 

PETE WILSON. Governor 



STATE WATER RESOURCES CONTROL BOARD 

THE PAUL R BONDERSON BUILDING 
X)1 P STREET 
JACRAMENTO. CA 95814 



Mailing Address 

DIVISION OF WATER RIGHTS 

P BOX 2000, Sacramento. CA 95812-2000 




916/657-2199 

FAX: 916/657-2388 



In Reply Refer 
to: 316:RAS 



MAY 1 1 1992 



dc-. 



Mr. John S. Gregg 
Program Manager 
Los Vaqueros Project 
Contra Costa 
1331 Concord 
Concord, CA 

Gentlemen: 



Water District 

Avenue 

94524 



Mr. Gary Darling 
Los Vaqueros Project 
Contra Costa Water District 
P.O. Box 4121 
Concord, CA 94524 



CONTRA COSTA WATER DISTRICT/U.S. BUREAU OF RECLAMATION DRAFT STAGE 2 
ENVIRONMENTAL IMPACT REPORT/ENVIRONMENTAL IMPACT STATEMENT FOR THE 
LOS VAQUEROS PROJECT (SCH NO. 91063072) 



Staff of the California State Water Resources Control Board (State Water 
Board), Division of Water Rights, Environmental Section, have reviewed the 

February 1992 Draft Environmental Impact Report/Environmental 
(Draft EIR/EIS) prepared by the Contra Costa Water District 
S. Bureau of Reclamation (Reclamation). Our comments follow: 



above-referenced 
Impact Statement 
(CCWD) and the U 



A. GENERAL COMMENTS 

In 1991 and 1992 three separate water right actions involving applications 
for new water rights and petitions to change existing water rights were 
filed with the State Water Board by CCWD and Reclamation relative to the 
proposed Los Vaqueros Project. These actions are: 

Application 20245 

On January 24, 1991 CCWD filed a petition to amend Application 20245, 

under California Water Code Section 1700 et seq., which was originally 

filed on June 5, 1961. Under amended Application 20245, CCWD proposes to 

divert up to 163,000 acre-feet (af) of water per year from Old River 

tributary to San Joaquin River, during the period of November 1 to 

June 30, at a maximum rate of diversion not to exceed 600 cubic feet per 

second (cfs). Water diverted will be collected at a point of rediversion 

to off stream storage in either Los Vaqueros Reservoir or Kellogg Reservoir 

for municipal , industrial, domestic, irrigation, recreation, incidental 

fish and wildlife preservation and/or enhancement, and water quality 

purposes throughout Contra Costa County. ncrrn/rn 

n t Cc I V t U 

^"^ MAY 1 2 1992 



MAY 2 6 1992 



Mr. John S. Gregg -2- 

Mr. Gary Darling (Errata) 



Application 25516 

On August 30, 1991 CCWD filed a petition, under California Water Code 
Section 10500, et seq., for partial assignment of state filing Application 
25516 which has a priority date of September 30, 1977. Under this 
petition, CCWD proposes to divert up to 14,800 af of water per year from 
Kellogg Creek tributary to Old River during the period of January 1 to 
December 31. The water will be diverted to onstream storage in either 
Los Vaqueros Reservoir or Kellogg Reservoir for the same purposes and 
place of use as identified above under Application 20245. 

Applications 5626, et al. 

Currently, CCWD has a contract with Reclamation for the delivery of up to 
195,000 af of water from Rock Slough under water right permits currently 
held by Reclamation. On November 22, 1991 and February 25, 1992 
Reclamation filed petitions, under California Water Code Section 1700, et 
seq., to: (1) add the proposed points of diversion and rediversion in 
CCWD's Application 20245 as points of diversion and/or rediversion in 
Reclamation's permitted Application 5626 and 16 other Reclamation permits, 
(2) add municipal and industrial purposes to Reclamation's permitted 
Applications 9364 and 9366, and (3) add CCWD's proposed place of use for 
CCWD's Applications 20245 and 25516 as a place of use under Reclamation's 
permitted Application 5626 and 16 other Reclamation permits. 

Since CCWD is the lead agency for the project, pursuant to the California 
Environmental Quality Act (CEQA), CCWD assumes primary responsibility 
under applicable California laws and regulations for: (1) preparing an 
adequate environmental document for the project, pursuant to CEQA, which 
fully discloses the potential environmental impacts of the project and 
feasible mitigation measures to avoid potential significant impacts or 
reduce them to nonsignif icance, and (2) implementing reasonable and 
feasible mitigation measures to avoid potential significant impacts of the 
project or reduce them to nonsignif icance. The State Water Board, as a 
Responsible and Trustee Agency for the project, must consider an adequate 
environmental document prepared by CCWD before it can consider approving 
the project and issuing the requested water right permits to CCWD and 
permit changes to Reclamation. 

As State Water Board staff has mentioned at several interagency staff 
meetings with CCWD's consultants preparing the Draft EIR/EIS, the scope of 
the project that was being defined in both interagency consultation 
meetings and in the recent administrative Draft EIR/EIS is much smaller 
than the maximum scope of the project that can be defined based on CCWD's ;- , 
applications and Reclamation's petitions currently pending before the 
State Water Board. Judging from the above-discussed pending applications 
and petitions, the overall scope of the project could involve a maximum 
diversion and/or rediversion of up to 372,800 af/yr from Rock Slough 

5-61 



MAY 2 6 1992 



Mr. John S. Gregg 
Mr. Gary Darling 



-3- 



(Errata) 



and Old River (including up to 14,800 af/yr from Kellogg Creek tributary 
to Old River). This figure of 372,800 af is derived by summing the above- 
discussed maximum annual diversion and/or rediversion amounts for 
contractual water service to CCWD under Reclamation's water rights 
(195,000 af) and CCWD's proposed new water rights for Applications 20245 
(163,000 af) and 25516 (14,800 af). Both the administrative and final 
Draft EIR/EIS, however, define the scope of the project as involving a 
maximum annual diversion from Rock Slough and Kellogg Creek tributary to 
Old River of only about 188,000 af. Thus, the scope of the project being 
defined in the Draft EIR/EIS is about half of the theoretical scope of the 
project currently pending before the State Water Board. 

Based on past experience, CCWD and Reclamation should understand that, 
given the existing environmental document, the State Water Board will 
likely develop permit terms which limit combined maximum annual diversions 
from the Delta by the project, under both CCWD's and Reclamation's water 
rights, to no more than the maximum levels identified in the Draft 
EIR/EIS. If this is acceptable to CCWD, please inform us in writing 
within 30 days of the date of this letter. Your response to this issue is 
important, since it will affect our ability under Section 4.A.(7)a. of the 
State Water Board's Agreement No. 1-905-300-0 with CCWD, to determine J 
whether the Draft EIR/EIS currently provides an adequate basis for "^ 
evaluating project impacts at a water right hearing. 

B. SPECIFIC COMMENTS 

1. Pages 1-10 through 1-11, Hydrologic Models: 

The discussion on use of the hydrologic model DWRSIM to assess effects' 
of the project alternatives on upstream rivers and reservoirs 
indicates that model simulations of the project at CCWD's full 
buildout level used the average critical year demands of 188,000 af/yr 
and average noncritical year demand of 174,600 af/yr derived from 
Table 1-1 on page 1-8. In view of the statement on page 1-10 (first 
paragraph) that maximum demands at full buildout could be as high as 
197,400 af/yr in critical years and 183,300 af/yr in noncritical 
years, we believe that model simulations should have' been run at these 
levels in order to estimate potential "worst case" environmental 
impacts of the project compared to the other alternatives. 
Consequently, we request that further model simulations be conducted 
covering this possible "worst case" scenario and that appropriate 
revisions be made in the Final EIR/EIS as to conclusions regarding the 
potential maximum environmental effects of the project at full 
buildout. 



5-2 



5-62 



P 



Mr. John S. Gregg -4- ^^^' ^1 ^'^52 

Mr. Gary Darl ing 



2. Page 1-11, Fischer Delta Model: 

Same comment as for Item B.l above, but directed with regards to c-j 
predictions of impacts on Delta salinities. 

3. Page 1-12, Los Vaqueros Operation Model: 

The discussion indicates that model runs were made of the project 

involving a new supplemental Delta intake operating at a rate of 

200 cfs whereas on page 2-17, the proposed design level for this 

facility is apparently 250 cfs. This inconsistency should be 

corrected in the Final EIR/EIS. Moreover, since CCWD has proposed in 5.4 

its water right Application 20245 a maximum design rate of up to 

600 cfs for this facility, either the model runs should be rerun using 

a maximum diversion rate of 600 cfs or CCWD should revise its 

Application 20245 to reduce its proposed maximum rate of diversion 

from 600 cfs to either 250 or 200 cfs. 

4. Page 1-13, Purpose of Joint Stage 2 EIR/EIS: 

The discussion lists major approvals or decisions needed for project 
construction and operation including: "issuance of water right 
permits by SWRCB to allow a storage reservoir and impoundment of 
Kellogg Creek waters". The words "Delta and" should be inserted after 
the word "impoundment". Also, no mention is made of the requirement 5-5 
for State Water Board approval of the pending Reclamation petitions to 
amend 17 of its water right permits as part of the project. These 
petitions are discussed in our general comments above and should be 
added in the Final EIR/EIS among the list of items requiring approval. 

5. Page 2-6, Third Paragraph: 

The discussion indicates that in wet and normal years the project 
would be operated to provide a 90-day emergency supply at the peak 
three-month demand level, but in dry and critical years the emergency 
supply would be reduced to 30 days at the peak one-month demand level 
due to use of up to 56,000 af of stored water for water quality ^"° 
blending and enhancement purposes. This change in operating criteria 
provides additional water supply in dry and critical years. This 
water supply feature of the project needs to be made more clear in the 
Final EIR/EIS as a key project purpose. 



6. Page 2-17, Supplemental Intake Facilities; 
See Comment B.3 above. 



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Mr. Gary Darl ing 



MAY ] 1 1992 



7. Page 3-13, Methodology: 

In this section, the Draft EIR/EIS states: "Existing conditions 

consists of the facilities, water supply demand, and operational rates 

that existed in 1990". For CEQA purposes, this statement is 

incorrect. It represents average conditions assuming a 1990 Level of 

Development (LOD). This is not an actual figure. For example, 

average annual CVP and SWP exports have never been as high as 6.15 5-8 

million af. Actual exports in the last 10 years have been much less 

than the the 1990 LOD. The use of the 1990 LOD overestimates present 

usage and therefore underestimates the effects of future increases. 

This paragraph should be rewritten to distinguish the difference 

between actual recent historical conditions, and 1990 LOD for modeling 

purposes. 

8. Page 4-10, Criteria for Conclusions of Significance: 

The last sentence of the second paragraph in this section states: 

"For species that are substantially affected by existing 
conditions (e.g., striped bass), impacts may be considered 
significant if the conditions contributing to existing 
effects are substantially worsened by project alternative 
operations. " 

We do not concur with this apparent assumption that any incremental 
impacts contributing to existing significant effects would not be 
considered significant unless the impacts themselves are substantial. 
To the contrary, in accordance with Section 15065(c) of the State CEQA 
Guidelines, any incremental change which aggravates an existing 
significant impact must be considered a significant cumulative impact. 
Therefore, the above identified quotation should be revised in the 
Final EIR/EIS to conform to the appropriate definition of a 
significant cumulative impact. Further, all incremental impacts of 
the project alternatives identified in this Draft EIR/EIS should be 
shown in the Final EIR/EIS to be significant cumulative impacts if 
they contribute by any degree to existing significant impacts. 

9. Pages 4-14 and 4-16, Losses from Entrainment: 

The Draft EIR/EIS states that under the No-Action Alternative 

entrainment of winter-run Chinook salmon and Delta smelt would be 

reduced because of less April diversion. What is the basis for 5-10 

assuming that diversions in April would be reduced and where are these 

reductions expected to occur? 



5-9 



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Mi^. Gary Darl ing 



10. Page 4-16, Delta Outflow Effects on Migration and Habitat Quality in 
the Bay: 

The last two sentences in this section are confusing and should be 
revised to clarify exactly what point is being made about the 
relationships of flow changes on organisms in Suisun Bay and San Pablo 
Bay. 

11. Page 4-24, Effects of Delta Cross Channel Diversions on Migration and - 
Survival : 

Under the discussion on future conditions with the project, the Draft 
EIR/EIS states that in model simulations comparing the Los Vaqueros 
Reservoir alternative to existing conditions, the increase in 
proportion of Sacramento River water diverted through the Delta Cross 
Channel would increase by less than one percent. If this one percent 
figure is an average value, then the maximum percentage (i.e., worst 
case) should also be given and the resulting impact assessment should 
take this worst case scenario into account. Also, how would this 
worst case scenario change if the model simulations were run at a 
maximum project diversion level of 197,400 af in critical years in 
accordance with Comment B.l above? 

Further, the Draft EIR/EIS states: 

"The Los Vaqueros Reservoir Alternative would slightly 
increase the chinook salmon mortality rate because it 
would slightly increase the number of outmigrant chinook 
salmon juveniles that would enter the central Delta as 
compared to the No-Action Alternative. Because of its 
small magnitude, this project-related impact would be less 
than significant." 

We do not concur with the conclusions drawn that impacts of the 
project on chinook salmon mortality is not significant. In the first 
place, we do not consider it appropriate for the impact analysis to be 
based on a comparison of the project to the No-Action Alternative 
since the No-Action Alternative assumes construction of new facilities 
to allow increases in annual Delta exports under the contract with 
Reclamation from the current maximum level of 130,000 af to 
195,000 af. Instead, the analysis should be based on a comparison of 
the project with existing conditions. Secondly, for reasons discussed 
in Comment B.8 above, the environmental impact of the project on 
chinook salmon mortality should be considered a significant cumulative 
impact and appropriate mitigation measures should be proposed. 



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Mr. Gary Darl ing 



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12. Pages 4-24 through 4-26, Lower San Joaquin River Flow Affects on 
Migration and Survival: 

With regard to assessment of project impacts on striped bass and Delta 
smelt, we have the same concerns as identified in Comment B.ll above. 
Conclusions regarding hydrologic changes based on model simulations 
should take into account the worst case scenario involving a maximum 
project diversion rate of 197,400 af in critical years. Impacts of 
the project should be based on a comparison of the project to existing 
conditions, not to a No-Action Alternative which includes up to 
67,400 af of increased Delta exports. Incremental impacts of the 
project on striped bass and Delta smelt mortality should be considered 
significant cumulative impacts. 

Further, the entire striped bass analysis is based on changes in the 
"striped bass abundance index" (38 mm index). Recent DFG modeling 
indicates that adult abundance is strongly affected by export and 
outflow rates during the rest of the year, not just during the April 
to July period. No consideration of the impacts of substantially 
increased fall and winter diversions on adult striped bass abundance 
is included in the Draft EIR/EIS. This needs be corrected in the 
Final EIR/EIS and mitigation measures proposed where appropriate. 

13. Pages 4-26 through 4-30, Losses to Entrainment: 

The Final EIR/EIS should include a determination as to whether the 
design criteria being followed for this proposed fish screen facility 
meets the standards and requirements of DFG and NMFS. Further, 
conclusions that the project would reduce fish entrainment losses 
based upon a comparison against the No-Action Alternative are 
inappropriate since the No-Action Alternative assumes increases in 
unscreened Delta exports of up to 67,400 af. Impacts of the project 
on entrainment of juvenile chinook salmon, striped bass, Delta smelt 
and American shad should be based on a comparison with existing 
conditions. Also, see comment B.12 above regarding the striped bass 
impact analysis. 

14. Page 4-30, Delta Outflow Effects on Migration and Habitat Quality in 
the Bay; Pages 4-30 through 4-31, Flow Effects on Habitat Availability 
and Migration in Rivers: 

Conclusions drawn that impacts of the project would not be significant 
because they involve small incremental changes should be reevaluated 
based on the above-discussed criteria for establishing a significant 
cumulative impact. 



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Mr. Gary Darl ing 



AY 1 1 1992 



5-16 



15. Page 4-31, Kellogg Reservoir Alternative: 
Same comments as above for Los Vaqueros Reservoir Alternative. 

16. Page 4-54, Mitigation Measures for Delta-Related Impacts: 

In this section, the Draft EIR/EIS acknowledges that the project would 
contribute to significant cumulative impacts on Delta fish, but 
implies that such cumulative impacts would occur only because of 
projected future developments by other agencies. An analysis of the 
potential cumulative impacts of these proposed future developments is 
presented on pages 4-43 through 4-51 of the Draft EIR/EIS. However, 
as discussed elsewhere in our comments herein, we believe the project 
would contribute to existing significant impacts in the Delta, and •>'^' 
such impacts should be considered as significant cumulative impacts 
regardless of whether or not these proposed future developments are 
constructed. Consequently, with regards to proposed mitigation 
measure 4-3, more attention should be focussed on steps CCWD and 
Reclamation can take independently to reduce the specific incremental 
impacts of the project, rather than relying on mitigation measures 
which may or may not be developed by other agencies for other 
projects. 

17. Page 4-55, Kellogg Reservoir Alternative: 

Same comments as above for Los Vaqueros Reservoir Alternative. 

18. Pages 7-18 through 7-19, Land Use: Recreation: 

The discussion indicates that impacts on botanical resources of 

expected changes in recreational uses in the project area have not 5-19 

been identified because a final recreation plan has not yet been 

developed. A final recreation plan should be provided in the Final 

EIR/EIS along with an analysis of expected impacts on botanical 

resources and necessary mitigation measures. 

19. Pages 7-35 through 7-44, Mitigation Measures for Impacts on Botanical 
Resources Common to All Alternatives: 

In general, the approach being taken towards developing appropriate 
measures to mitigate these impacts appears adequate at this stage. 
However, most of the recommended items involve further site-specific -'"^^ 
surveys and investigations to determine what specific mitigation 
measures will actually be needed. Such site-specific surveys cannot 
be considered by themselves to be mitigation measures, but only a 
means to determine what those actual mitigation measures should be. 
Therefore, with regards to the selected alternative, the Final EIR/EIS 



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Mr. John S. Gregg 
Mr. Gary Darl ing 



-9- 



IViAY 1 1 1992 



should provide more site-specific detail as to the actual on-the- 
ground measures that should be implemented to accomplish the 
mitigation objectives. Particular attention should be directed 
towards achieving no net losses to wetland habitats and special status 
plant species. 

20. Pages 7-45 through 7-47, Additional Mitigation Measures for Impacts on 
Botanical Resources of the Los Vaqueros Reservoir Alternative: 

In this section, recommended measures are proposed to accomplish 
mitigation for the impacts on botanical resources of the Los Vaqueros 
Reservoir Alternative not previously addressed in measures common to 
all the alternatives. Again, as discussed in Comment B.19 above, the 
approaches being recommended are adequate for this stage of the 
planning process, but involve further site-specific surveys and 
investigations to determine the actual mitigation measures needed. 
Since the Los Vaqueros Reservoir Alternative is likely to be the 
selected alternative, we expect the Final EIR/EIS to provide a more 
detailed and site-specific mitigation plan for this alternative. In 
particular, more detail needs to be provided on exactly how 
compensation for the unavoidable loss of 180 acres of mature valley 
oak woodland habitat will be accomplished. Further, we do not concur 
with the assumption given that losses of such oak woodland habitat 
values, which would not be replaced for over 75 years, can be 
considered as short-term losses. These losses should be considered as 
long-term, significant impacts because they span a period far beyond 
the planning period for the entire project, which does not appear to 
extend beyond the year 2035. In view of this, additional measures 
need to be developed to compensate for such significant losses. 

21. Pages 7-47 through 7-48, Kellogg Reservoir Alternative: 

Same as Comment 8.20 above for Los Vaqueros Project in the event this 
alternative becomes the selected alternative. 



5-21 



5-22 



22. Page 8-23, Summary of Impacts on Wildlife Common to All Alternative 
Configurations and Conclusions of Significance: 

Under the topic of Common Wildlife Species, the discussion states: 

"Loss of 185 acres of valley oak woodlands and savanna 
would also be considered a less-than-signif icant impact on 
wildlife even though this habitat is important for 
wildlife species. Oak woodlands are common in the project 
area, and over 4,000 acres of blue oak woodlands would be 
purchased and protected by CCWD." 

We do not concur that these losses should be considered 
nonsignificant. Senate Concurrent Resolution No. 17 (September 1, 



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Mr. John S. Gregg -10- I^AY 1 1 1992 

Mr. Gary Darling 



1989) specifies that state agencies exercising land use planning 
duties and management with respect to public and privately owned oak 
woodlands undertake measures "to preserve and protect native oak 
woodlands to the maximum extent feasible and consistent with the 
performance of their duties and responsibilities, or provide for 
replacement plantings where Blue, Engelman, Valley, or Coast Live Oak 
are removed from oak woodlands". In view of this, the Final EIR/EIS 
should identify these losses as significant and identify specific 
measures by which the 4,000 acres of blue oak woodlands to be 
purchased by CCWD would be managed to enhance wildlife habitat values 
in full compensation for these losses. 

23. Pages 8-40 through 8-45, Mitigation Measures for Impacts on Wildlife 
Resources: 

With the exception of valley oak woodland habitat, the mitigation 

measures proposed appear to be adequate at this stage. However, as in 

the case of mitigation for impacts on botanical resources, more 5-24 

detail, in terms of site-specific plans, should be identified for the 

preferred alternatives in the Final EIR/EIS. With regards to valley 

oak woodland habitat losses, specific measures should be proposed to 

manage the 4,000 acres of Blue Oak woodland habitat purchased by CCWD 

to enhance wildlife habitat values in compensation for these 

significant losses. 



24. Page 11-3, Cultural Resources Studies Undertaken to Date: 

Reference the latest technical studies (1991 Bramlette, et al. and 
1991 Praetzellis, et al.) in the last two paragraphs. 



5-25 



25. Page 11-4, First Paragraph: 

To be a full disclosure document, the Final EIR/EIS needs to include 

more than an inventory of cultural resources. The Determinations of 

Eligibility (DOE) for inclusion in the National Register of Historic 

Places (NRHP), assessment of effects and mitigation measures must also 5-26 

be included. A Programmatic Memorandum of Agreement (PMOA) identifies 

the procedures to develop the cultural resources management plan that 

will outline the mitigation measures. The Army Corps of Engineers and 

the State Water Board should also be included. 

26. Page 11-6, Fourth Paragraph: 

Reference is made to a "tentative APE". There is an existing APE for 

this project. It should not be referred to as tentative. It is 

understood that there will be project changes, but these should be 5-27 

able to be incorporated if the original work has been inclusive and 

the PMOA is flexible. Changes should also be reviewed by the 

appropriate agencies. 

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Mr. John S. Gregg 
Mr. Gary Darl ing 



■11- 



MAV i 1 ]yy^ 



27. Pages 11-8 and 11-9, Impact Mechanisms: 

Include "mitigation compensation areas" as an additional impact 

category. Mitigation lands utilized to compensate for other values 5.28 

(i.e., wildlife, botanical, visual and recreation resources) need to 

be inventoried for cultural resources. Such resources then need to be 

evaluated, assessed for effects and appropriate mitigation needs to be 

implemented in accordance with the Section 106 consultation process. 

28. Page 11-9, Reservoir Operation: 

The statements that fluctuating reservoir levels and changes in 

amounts of water released "could" cause erosion need to be more 5-29 

definitive. It is not just a possibility, it is a fact and needs to 

be addressed as such. 



29. Page 11-10, Assessment of Impacts: 

This needs to be rewritten to reflect the recent cultural resources 
work--it is too tentative. Again, the DOE and assessment of effects 
must be included in the final document. Additional information also 
needs to be provided regarding Native American concerns. 

30. Page 11-11, Recreational Facilities: 

The document states that recreational facilities: 

"...could result in direct and indirect impacts on 
cultural resources". 

Recreational facilities wil 1 result in impacts on cultural resources. 

State Water Board staff requested they be handled as a direct impact 

in previous comments on the technical document referenced as 1991 
Bramlette, et al. 

31. Pages 11-10 through 11-20, Summary of Impacts and Conclusions of 
Significance Sections for each of the Project Configurations: 

All of these sections should be rewritten to accurately reflect the 
updated cultural resources work as it is necessary to include the DOE 
and assessment of effects for all sites in the Final EIR/EIS. The 
possibility of buried sites and their treatment should be included in 
the cultural resources management plan. 



5-30 i 



5-31 



5-32 



5-70 



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Mr. John S. Gregg 
Mr. Gary Darling 



•12- 



IVIAY 



1 1 199? 



32. Page 11-20, Mitigation Measures: 

The first sentence states: 

"As impact areas for the preferred alternative are further 
refined, each site potentially affected by the preferred 
alternative will be assessed to determine the appropriate 
method of mitigation or avoidance." 

By the time the Final EIR/EIS is completed, it should already be 
determined which sites will be affected so that this section can be 
updated to propose the necessary site-specific mitigation measures. 

33. Pages 11-20 through 11-24, Site Avoidance Measures: 

CEQA (Section 21002) requires that "public agencies should not approve 
projects as proposed if there are feasible alternatives or feasible 
mitigation measures available which would substantially lessen the 
significant environmental effects of such projects and that the 
procedures required by this are intended to assist public agencies in 
systematically identifying both the significant effects of proposed 
projects and the feasible alternatives or feasible mitigation measures 
which will avoid or substantially lessen such significant effects." 

Avoidance of cultural resources is the preferred mitigation measure in 
both the state and federal processes. Excavation of sites to recover 
a small sample of data that may answer scientific questions is a 
destructive process in itself. Fencing and monitoring of sites also 
has been proven to be ineffective, often inadvertently drawing more 
attention to the sites. On page 11-21, discuss possible fencing or 
signing alternatives. This entire section should be revised to 
reflect that site evaluation, assessment of impacts and Section 106 
compliance are required prior to permitting by the state and federal 
agencies. 

34. Pages 11-21 through 11-23, Recommended Site Preservation and 
Protection Measures: 

Fencing and monitoring plans and cultural resources management plans 
will not necessarily ensure protection of sites. Impacts may be 
reduced but they cannot "ensure protection". 

35. Page 11-21, Measures 11-4 and 11-5: 

Regarding Measure 11-4, edit the last sentence for " how and when the 
Section 106 compliance will occur." This is incorrectly used; clarify 
as also was previously requested in the review of the technical 
document (1991 Bramlette, et al.). Regarding Measure 11-5, the 
facilities design and landscaping should also be reviewed by SHPO. 



5-33 



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5-35 



5-36 



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Mr. Gary Darling 



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36. Page 11-22, Measure 11-6: 

This information is also necessary for the water rights process. 
There needs to be more information provided, including but not limited 
to: (a) determination of Native American involvement and the nature 
of their uses of the area from the past through the present time 
(i.e., habitation, religious/ceremonial, resource procurement areas 
and trail and trade networks), (b) documentation of Native American 
interest in the cultural deposits, (c) the range of their concerns 
regarding the proposed project and its potential impacts on both the 
ethnographic resources and the environment; and (d) an assessment of 
impacts and recommendations for mitigation of any impacts resulting 
from the proposed project. 

37. Page 11-22, Site Evaluation and Data Recovery Measures: 

Evaluation of eligibility cannot be considered as a mitigation 
measure. This section should be edited in light of the current 
direction of cultural resources evaluations. References to "OHP" 
throughout the document should be edited to reflect the correct 
acronym of "SHPO". 

38. Page 18-9 through 18-11, Cumulative Impacts of Los Vaqueros Reservoir 
Alternative on Vegetation and Wildlife Resource: 

See comments B.19, B.20, B.22 and B.23 above. 



40, 



5-37 



5-38 



5-39 



39. Page 18-11, Cultural Resources: 



fully 



This cumulative impact analysis is incomplete. It needs to be 
developed to include at least the following: (a) what are the 
possible cumulative impacts on cultural resources that could be caused 
by the project alternatives?, (b) what are the types of sites present 
and how have they been historically impacted? and (c) address the 
types of "reasonably foreseeable probable future projects" that may 
affect the cultural resources. Even with mitigation, overall 
cumulative impacts of past, current and future projects can be 
significant. 

Pages 19-1 through 19-2, Significant and Unavoidable Impacts of Los 
Vaqueros Reservoir and Kellogg Reservoir Alternatives: 

In view of our comments above regarding the environmental impact 
analysis in Chapters 4, 7 and 8 of this Draft EIR/EIS, additional 
items should be added concerning the potential significant cumulative 
impacts on Delta fish, botanical resources (particularly valley oak 
woodland) and wildlife resources (particularly valley oak woodland 



5-40 



5-41 



5-72 



Mr. John S. Gregg -14- ^^"^ ^ ^ ^392 

Mr. Gary Darling 



habitat) if the revised mitigation measures in the Final EIR/EIS are 
not sufficient to mitigate these impacts to nonsignif icance. Further, 
if the revised mitigation measures are considered to fall short of 
full mitigation for these impacts, CCWD should be advised to consider 
adopting a statement of overriding considerations upon approval of the 
Final EIR/EIS and final project. 

41. Pages 19-4 through 19-8, Environmental Commitments: 

This section takes a very important step towards identifying the 

specific mitigation measures CCWD and Reclamation will need to 

implement in order to assure that the project is carried out without 

causing significant environmental damage. However, as discussed in 

our comments above, additional mitigation measures are needed and many 

of the measures currently identified involve further site-specific 

studies and investigations which are not themselves mitigation 

measures, but only a means to identify the final site-specific 

mitigation plans. To the extent possible, the Final EIR/EIS should 

identify in this section those site-specific plans for the selected 

alternative. Further, site-specific monitoring measures should be 5.42 

added, pursuant to CEQA, Section 21081.6, to assure that the 

mitigation measures implemented actually accomplish the mitigation 

objectives. This information will need to be made available to the 

State Water Board prior to its water right hearing on the proposed 

water right applications and petitions for the project. 

With regards to mitigation measures for impacts on cultural resources 
identified on page 19-7, Measures 11-6 and 11-7 should be changed to 
reflect the current cultural resources work. Measure 11-6 
(consultation with Native American Groups) is a continuing process, 
not a mitigation. Regarding Measure 11-7 (Evaluation of sites and 
data recovery), the evaluation of sites will soon be completed. 

42. Page 20-1, Staged Environmental Review Process: 

This section describes the staged environmental review process being 
undertaken by CCWD. If the Final Stage 2 EIR/EIS does not include 5-43 
final site-specific mitigation plans for the project, will a 
supplemental (i.e., Stage 3) environmental document be prepared to 
disclose this information? 

43. Page 20-16, National Historic Preservation Act: 

The discussion states: "If the project is determined to have an 

adverse affect on NRHP-listed properties or those eligible for listing 5-44 

in the NRHP the agency is required to consult with the SHPO " The 

regulations require an agency to do the DOE in consultation with SHPO. 



5-73 



Mr. John S. Gregg 
Mr. Gary Darl ing 



•15- 



MAY i i 1992 



44. Page 20-17, American Indian Religious Freedom Act of 1978: 

This section states: "The discussions between CCWD, Reclamation and 
Native American representatives revolved around the reinternment. . . . " 
Is this a correct statement? Were the discussions primarily regarding 
reinternment? 

Thank you for the opportunity to conment on the Draft EIR/EIS. If you have 
any questions, please call me at 916/657-1981 or call Mr. Ross Swenerton, 
Chief, Environmental Review Unit 2, at 916/657-2199. Mr. Swenerton is the 
staff person currently assigned to coordinate environmental review of this 
project. 

Sincerely, 



5-45' 



n^yz^^.^X^'^^'f 



Gerald E. 
Assistant 



Johns 
Division Chief 



cc: Mr. Douglas Kleinsmith 

U.S. Bureau of Reclamation 
Environmental Compliance Branch 
Division of Planning 
2800 Cottage Way, Room W-2103 
Sacramento, CA 95825-1898 



5-74 






Responses to Comments of the California State Water Resources Con trol Board 

5-1. CCWD has two water rights applications pending before the Califomia State Water Resources 

Control Board (SWRCB) for the Los Vaqueros Project. Application 20245 is for diversion into 
storage of up to 163,000 af/yr at the Ijds Vaqueros Resen/oir site or, alternatively, up to 135,000 
af/yr at the Kellogg Reservoir site. Application 25516 is a partial assignment of a state filing for 
diversion from Kellogg Creek. Application 25516 includes a storage component of 10,800 af/yr 
at the Lx)s Vaqueros Reservoir site and 14,800 af/yr at the Kellogg Resen/oir site. In addition, 
application 25516 includes a small direct diversion component from Kellogg Creek. 

Although CCWD had determined which alternatives would be addressed in its EIR/EIS for the Los 
Vaqueros Project, CCWD filed these water rights applications with SWRCB before completing its 
extensive alternatives analysis and before it completed the draft Stage 2 EIR/EIS. The water right 
applteation process provides the ability to reduce the quantities and rates of water diversion but 
does not allow the rate to be increased without refiling the application. 

To ensure that feasible alternatives were not eliminated and to minimize potential schedule delays 
caused by the need to refile an application if changes in the project occurred, CCWD intentionally 
filed applications for larger quantities of water and greater rates of diversion than its projected 
need. The Stage 2 EIR/EIS, however, only analyzes, and provides environmental documentation 
for, arternatives consistent with CCWD's identified water quality and reliability objectives. 

The water rights applications will be reduced to be consistent with CCWD's staff-preferred 
alternative identified in the Stage 2 EIR/EIS. Making the water rights applications consistent with 
CCWD's proposed action that was addressed in the Stage 2 EIR/EIS will involve reducing the 
quantity of water that can be diverted to storage to 100,000 af reducing the diversion rate at the 
new supplemental intake from 600 cfs to 250 cfs, and eliminating the Kellogg Resen/oir site from 
the water rights application. 

CCWD has not provided adequate environmental documentation under either CEQA or NEPA to 
constmct or operate a project other than that considered in the Stage 2 EIR/EIS. In addition, 
CCWD's draft amended water service contract with Redamatkxi specifically states that "in utilizing 
its CVP water supply in conjunctkwi with its Los Vaqueros water rights water, the District shall not 
deliver within its existing service area, in any one year, a quantity of water in excess of 195,000 
acre-feet." 

Therefore, the total amount of water avaNaWe for use within CCWD's service area under both Los 
Vaqueros water rights and through CCWD's contract with Reclamation is 195,000 af. 

5-2. CCWD's identified demands are 188,000 af/yr in critrcal years and 174,600 af/yr in noncritical 

years. The referenced statement indk^ates that there are variables that could affect CCWD's 
demands In any single year. CCWD and Redamatkxi believe that additional model mns are not 
necessary for two reasons. First, events that coukj lead to CCWD exceeding its projected 
demands are Impossible to predict but would occur only infrequently, if at all. It is important to 
note that in critical years, a substantial portton of CCWD's demands consist of industrial diversions 
that normally occur directly from the San Joaquin River unless water quality in the river is 
extremely poor. These demands are diffrcult to precisely project. 

In additkxi, modeling these demands would not provide substantial additional information. 
Changes in diversions of approximately 9,000 af/yr would not measurably alter flows or salinities 
in the Delta or flows upstream when diversions from the Delta total neariy 6 million af/yr. 



Respons« (o Comments of the CalHomia State Water Resources Control Board 

5-75 



5-3. See response to comment 5-2 above. 

5-4. Comment noted. The maximum diversion rate of the proposed Old River intake is 250 cfs. This 

correction has tseen made in the final Stage 2 EIR/EIS. See also response to comment 5-1 above. 

5-5. ComnDerrt noted. CCWD and Reclamation recognize that the SWRCB has these additional 

responsikHlities. 

5-6. The proposed operation of the project In dry and critical years would require the use of an 

additional 26,000 af for water quality Wending. CCWD wouJd reduce its diversions from tf>e Delta 
by an equivalent anrxMjnt to meet its water quality objectives and therefore, the proposed project 
would not result in increased water supplies. See also response to comment 5-1 above. 

5-7. See response to comment 5-4 above. 

5-8. The denund levels used reasonable estimates of current demands arxi the analysis and 

conclusions are appropriate. The demands used In the operations studies were selected as 
representative of current demands. Actual exports are often less than demands, especially in 
drought conditions. Thus, it would not be expected that actual average annual export levels of 
the CVP and SWP (which hiave increased over the last 10 years) would be as high as reasonatjie 
estimates of current demand levels. In these studies, export levels fell below demand levels in 
drought periods and were not overestimated. 

5-9. As described throughout Chapter 4 of thie EIR/EIS, "Delta System Fisheries Resources", most 

Impacts associated with the proposed project are extremely minor and are therefore considered 
less tfian significant in terms of the project's direct Impacts on fishery resources. Whenever the 
proposed project would result in slight additional Incremental Impacts under future conditions, 
however, the Stage 2 EIR/EIS identifies these Impacts as contributing to significant cumulative 
impacts. 

5-10. Tfie analysis in the EIR/EIS irxJicates that reverse flows would be less frequent than under existing 
conditions. This reduction would benefit Delta smelt. 

Total diversions from the Delta in April would be reduced under future conditions according to 
model simulations in the EIR/EIS because upstream reservoir storage would be reduced and the 
frequency of years when there would be water available for diversion in April would also be 
reduced. 

5-1 1 . Tfie intent of the last two sentences in the referenced section are to indicate that, to the extent that 
there would be any effects, they would occur primarily in tfK>se portions of the Bay system closest 
to the Delta because the extremely small magnitude of the chianges would be unmeasurak)le 
farther kite the Bay system, and any effects would be very minor k>ecause the proportional 
reduction In Delta outflow Is minor. 

5-12. CCWD and Reclamation believe that the comparison of the proposed project to the No-Action 
Alternative is appropriate for purposes of CEQA and NEPA compliance. The proposed project 
would not greatly increase CCWD's ability to deliver water from the Delta to its service area. 
Although the proposed project would eliminate the need to make improvements to a portion of 
CCWD's water conveyance system, major restrictions would still exist In the Contra Costa Canal 
system tfial would limit CCWD's deliveries to approximately existing conditions. Improvements 
necessary to increase CCWD's ability to deliver water to Its service area under any of the 
alternatives are descritted on pages 2-2 through 2-4 of the EIR/EIS. 



Response to Comments of the California Staite Water Resources Control Board 

5-76 



In addition, the paragraph following the referenced paragraph does in fact identify the impact as 
a significant cumulative impact. 

5-13. See responses to comments 5-2 and 5-12 above. CCWD believes that the modeling it has 
conducted to determine Impacts on striped bass is appropriate, particularly because CCWD 
diversions would be substantially reduced In fail of nx>st years because CCWD would be relying 
on water stored in the Los Vaqueros Reservoir. Increases in impacts on striped bass are generally 
identified as significant in the EIR/EIS. 

5-14. See responses to comments 5-12 and 5-13 above. CCWD is wor1<ing directly and closely with the 
Caltfomia Department of Fish and Game and the National Marine Fisheries Service regarding fish 
screen design. CCWD is designing the fish screen to meet the criteria identified by these 
agencies. Lx)sses to entrainment under the project eiltematives are compared to both existing 
conditions and to the No-Action Alternative. 

5-15. CCWD believes, based on available infomnation, that there is no indication that the minor 
reductions in Delta outflow caused by the project wouid contribute to cumulative impacts on 
fisheries In San Francisco Bay. In addition, under the No-Action Alternative, reductions in Delta 
outflow were determined to have a less-than-significant effect. 

5-16. See responses to comments 5-1 through 5-15. 

5-17. As a result of comments received on the draft EIR/EIS and meetings with the various resource 
agencies, CCWD and Reclamation have developed mitigation measures that not only reduce 
impacts to Delta resources, txit actually improve conditions as compared to no project, particularly 
for winter-run chinool< salmon. These measures consist of revisions to the proposed project 
operations in terms of the timing and magnitude of diversions from the Delta. Under the proposed 
mitigation plan, CCWD will use a portion of the water stored in the Los Vaqueros Reservoir in lieu 
of direct diversions from the Delta during the winter-run Chinook salmon's season of highest 
vulnerat>illty. This operation will allow CCWD to eliminate all its diversions from the Delta, including 
those from its existing intake at Rock Slough, for a total of approximately 30 calendar days 
between March 15 and May 15 of each year. In addition, CCWD will generally not fill the Los 
Vaqueros Reservoir between March 15 arxJ May 31. 

The revised project operations are fully described in the biological assessment for the proposed 
project as are the effects of the revised operations on special-status fish species. The mitigated 
operations are also described in Chapter 4 of the final Stage 2 EIR/EIS, along with a discussion 
of effects on other fish species. 

5-18. See response to comment 5-17, above. 

5-19. The Stage 2 EIR/EIS fully discloses the expected impacts of recreation in the Kellogg Creek 
watershed from recreational development. As noted on page 7-18, impacts on tx>tanical resources 
are not expected because the project description incorporates management guidelines that state 
that Impacts on botanical resources shall be avokjed, the adopted conceptual recreation plan 
includes proviskxis to protect botank^al resources, and recreatkxi use will be monitored by CCWD. 
The potential effects of the recreation plan on other resources and issues. Including traffic, air 
quality, and cultural resources, are also fully analyzed in the EIR/EIS. The Stage 2 EIR/EIS 
recognizes, however, that the conce^^uai recreation plan may change before it is Imptennented. 
If changes occur, CCWD will, as lead agency, develop a final recreation plan, prepare appropriate 
documentation under CEQA and recommend appropriate mitigation nrteasures. 

5-20. Only mitigatksn measure 7-1 identifies that additk>nal surveys may be required. This mitigation 
n^easure has been proposed by CCWD because, as indicated on page 7-35, very small portions 



Response to Cowmerrts of tfw California State Water f^sources Control Board 

5-77 



(about 20 acres) of the project area (over 20.000 acres) have not yet been surveyed because of 
lack of property access. This mitigation measure requires surveys and wetland delineations If 
project features are proposed in any areas that have not yet been surveyed. The final paragraph 
of the mitigation measure identifies specific actions that will be required if sensitive botanical 
resources are found. 

5-21. CCWD beJieves that the mitigation nneasures developed and Included In the Stage 2 EIR/EIS are 
adequate. In addition, more detailed Infonrtatlon regarding the proposed wetland mitigation plan 
and valley oak woodland plan have been developed and are Included as appendices to the final 
EIR/EIS. The valley oak woodland mitigation plan contains measures, such as establishing bird 
boxes and brush piles, to partially offset losses of short-term wildlife habitat. 

5-22. See response to comment 5-21 above. 

5-23. Valley oaks were avoided where practicable during project planning. However, some could not 
be avoided because they are within the reservoir Inundatkxi zone. The Stage 2 EIR/EIS identifies 
the loss of approximately 180 acres of valley oak woodlands as a significant Impact on a 
significant natural vegetation community and proposes mitigation measures to reduce this Impact 
to a less-than-signlflcant level. Although valley oak woodlands are considered a significant natural 
community, the stand of valley oaks in the Kellogg Creek watershed does not support particularly 
unique wildlife values when viewed In the context of adjacent areas controlled by CCWD that 
provide equivalent habitat values. Therefore, loss of these woodlands would have a less-than- 
significant Impact on area wildlife. In addition, CCWD believes that it is unimportant in which 
section of the EIR/EIS the impact is identified as significant. The impact Is considered significant 
and mitigation measures have been proposed by CCWD. 

5-24. Descriptkxis of watershed management have t^een expanded in the biological assessment and 
Incorporated into the biological opinion for terrestrial species. 

5-25. Comment rwted. This correctkxi has been included In the final EIR/EIS. 

5-26. Chapter 1 1 of the final EIR/EIS contains a description of activrties conducted in compliance with 
Section 106 of the National Historic Preservation Act since publication of the draft EIR/EIS. 
Attachment 3 includes a letter from the State Historic Preservation Officer (SHPO) expressing 
concurrence with these findings. 

CCWD, Reclamation, the Corps, the SWRCB, and the SHPO have developed and executed a 
programmatic memorandum of agreement (PA) that will determine how mitigation will be 
conducted for properties eligible for listing In the National Register of Historic Places. The PA is 
eilso iTK^uded in Attachment 3. 

5-27. At the time the draft EIR/EIS was published, an area of potential effect (APE) had not yet been 
firmly established. Since publicatk>n of the draft EIR/EIS, substantial progress has been made in 
complying with Section 106. This progress is discussed in Chapter 11 of the final EIR/EIS. 

5-28. Comnrtent noted. This correctkxi has been included in the final EIR/EIS. 

5-29. The sectkxi discussed in this comment was written to generally describe potential Impact 
mechanisms, not to descrit)e impacts. Impacts of reservoir operation under the proposed action 
are descrit>ed on page 11-11 of the EIR/EIS. 

5-30. Comment noted. As described In response to comment 5-27, above, substantial progress has 
been made In complying with Sectk>n 106 since publication of the draft EIR/EIS. This progress 
Is discussed in Chapter 11 of the final EIR/EIS. 



Response (o Ck>mm«nls of the Calrfomia Stale Water Resources Cootrol Board 

5-78 



5-31. CCWD and Reclamation recognize tliat prehistoric and historic sites within the project APE will be 
affected by the recreation facilities and will treat these sites as appropriate pursuant to the PA. 

5-32. CkMTinnent noted As described In response to connment 5-27, above, substantial progress has 
been made in complying with Section 106 since publication of the draft EIR/EIS. This progress 
is discussed In Chapter 11 of the final EIR/EIS. The possibility of buried sites and the steps 
necessary to comply with Section 106 are included in the PA. 

5-33. See response to comment 5-27, above. 

5-34. The Stage 2 EIR/EIS dearly recognizes on page 1 1-20 that avoidance is the preferred mitigation 
measure. The fencing measure discussed on page 1 1-21 is specifically aimed toward preventing 
incidental impacts from constructton activities and would be a short-term measure that would allow 
construction monitors to clearly delineate to construction crews areas to avoid. CCWD and 
Reclamation recognize that compliance with Section 106 is necessary before receiving permits 
from certain state and federal agencies arxJ has proceeded wtth studies ttased on that l<nowtedge. 
The process is descriJDed on page 11-21. 

5-35. The intent of the mitigation measures is to reduce the impacts caused by the proposed action to 
a less-than-significant level. CCWD and Recianr^tion recognize that these measures will not 
ensure protection from all possitale non-project-related impacts but believe that the measures 
described in the EIR/EIS are appropriate and will reduce Impacts to less-thian-significant levels. 

5-36. Compliance with Section 106 is described in Chapter 11 of the final EIR/EIS. 

5-37. The information discussed in this comment was developed by CCWD and was provided to the 
SWRCB staff for use as part of the water right hearings for the Los Vaqueros Project. 

5-38. The mitigation measure referenced in this comment does not rely on site evaluation as mitigation. 
Site evaluation is coupled with data recovery rf the sites were determined to be eligible for listing 
in the NRHP. 

All references to "OHP" have been changed to "SHPO" in the final EIR/EIS. 

5-39. See responses to comments 5-20, 5-21. 5-23, and 5-24 above. 

5-40. CCWD t)elieves that the cumulative impact analysis is appropriate. Implementation of the PA will 
result In a finding of no adverse effect and the Los Vaqueros Project would therefore not 
contribute to significant cumulative impacts. 

5-41 . CCWD believes that the measures proposed to mitigate vegetation and wildlife impacts throughout 
the Stage 2 EIR/EIS as supplemented in the biological assessment are adequate to mitigate 
impacts to less-than-significant levels. CCWD has worked closely with resource agencies 
responsible for approving aspects of the proposed project and believes that these issues have 
been adequately addressed. 

5-42. CCWD t>elieves thtat tf>e mitigation program it has developed is adequate to reduce impacts to 
less-than-slgnlficant levels. This program is fully described in the final EIR/EIS. in addition, as 
part of the approval process for the proposed project, CCWD will adopt a mitigation monitoring 
and reporting plan consistent with CEQA. See also responses to comments 5-25 through 5-38. 

5-43. See response to comment 5-42 above. CCWD believes that the environmental documentation it 
hias developed for the Los Vaqueros Project provides an appropriate t>asis for responsible 
agencies to mal<e permitting decisions, and no additional environmental documentation is planned. 



Response to Comments of the California StaM Water Resources Control Board 

5-79 



5-44. Comment noted. 

5-45. Native American coordination and consultation has been conducted by CCWD and Reclamation 
to elicit opinions concerning the entire Los Vaqueros Project, including the reinterment of human 
remains. 

SHPO's written concun-ence with Reclamation's determination of eligibility and determination of 
effect has been received and is included in the final EIR/EIS. In part, the letter concurs that with 
implementation of the PA, the project will have no adverse effect. 



Response to Comments of the Califomia State Water Resources Control Board 

5-80 



STATE Of CAllFOfiNIA— THE RESOURCES AGENCY 



LETTER NO. 6 

O PO ROC DCUK i^ M JIAN. Governor 



DEPARTMENT OF FISH AND GAME 

POST OfFICE BOX 47 
YOUNTVIILE. CALIFORNIA 94599 
(707) 944-5500 







June 1, 1992 



CC-. -y^i^ 



Mr. John S. Gregg 
Program Manager 
Los Vaqueros Project 
Post Office Box 4121 
Concord, California 94524 

Dear Mr. Gregg: 

Draft Stage 2 Environmental Impact Report/ 

Environmental Impact Statement (EIR/EIS) 

Los Vaqueros Project 

Department of Fish and Game personnel from the Department's Region 3 
office have reviewed the subject document which evaluates the construction of 
a 100,000-acre foot storage reservoir on Kellogg Creek in eastern Contra Costa 
County. Our comments relate only to project impacts associated with the 
reservoir site since the point of diversion for the reservoir is in the 
Department's Region 2. Time and personnel constraints have limited our review 
of the document. Concerns regarding the project's effects on Delta and 
Sacramento/San Joaquin River fishery resources were incorporated into the 
Department's comments to the State Water Resources Control Board on Water 
Applications 20245, 25526, and Permit Application 5626, et al . 

Department staff have been working with the Contra Costa Water District 
and its consultant for several years to address impacts associated with the 
proposed reservoir and associated realignment of Vasco Road and various 
utility corridors. We have provided comments on previous California 
Environmental Quality Act documents (Stage 1 EIR and Vasco Road Realigrrment 
EIR) . In a letter dated January 14, 1992, we provided comments to the 
District on the Stage 2 Administrative Draft. The comments included in that 
letter should be addressed in the final document. 

Based upon our review of the document, we believe that it provides an 
adequate assessment of impacts associated with the proposed project and the 
various project alternatives (i.e., Desalinization, Kellogg Reservoir, Middle 
River Intake/EBMUD Emergency Supply, and No Project) on terrestrial and 
aquatic resources within Region 3 (Contra Costa County west of Highway 4) . 
The proposed reservoir, while incurring impacts to wetlands, oak woodlands, 
grasslands, and several sensitive plant and animal species, also provides 
substantial benefits to wildlife through watershed acquisition and proposed 
mitigation measures. 



6-1 



6-2 



JUN - h 1992 



5-81 



Mr. John S. Gregg 
June 1, 1992 
Page Two 



Of prime concern to the Department are negative effects on wildlife 
which would be associated with recreational development of the reservoir. No 
discussion of these impacts is incorporated in the DEIR. Placement of these 
facilities, along with other facilities required for operation and maintenance 
of the reservoir, could significantly affect wildlife use of the affected 
areas, as well as mitigation sites if in close proximity to such facilities. 
Of particular concern and not discussed in the document are the effects of 
these facilities on species such as the San Joaquin kit fox. An example is 
the effect of proposed facilities along the southwestern shore of the Los 
Vaqueros Reservoir and their effect on kit fox movement from the eastern side 
of the reservoir to the west and to the Round Valley area. The effect of 
habitat fragmentation resulting from the reservoir and associated facilities 
should be addressed to allow a complete assessment of the effects of the 
project on these species and other wildlife. 

The issue of what is appropriate mitigation for kit fox impacts 
associated with the reservoir is not specifically addressed in the document. 
The Department believes that watershed acquisition will offset impacts 
associated with the reservoir itself but not the effects of the realigned 
Vasco Road. We recommend acquisition of habitat within the Herdlyn area as 
the appropriate method of addressing these effects. This recommendation is 
based on the fact that the road affects habitat which is known to be occupied 
by the species (based on sightings) . The road also will introduce a new 
obstacle to kit fox movement in a previously undisturbed setting. The Herdlyn 
area is a known use area for kit fox and is in close proximity to a recently 
documented occurrence to the north. While a large portion of the reservoir 
acquisition area is suitable kit fox habitat, no actual observations of the 
species in the area were made during project surveys. 

The Department concurs with proposed mitigation measures for wetland and 
valley oak woodland impacts. Specific mitigation plans should be incorporated 
in the final document. 

The Department is concerned that the document does not provide specific 
measures to address impacts to California tiger salamanders, red-legged frogs, 
and western pond turtles. Unspecific proposals to relocate turtles and frogs 
from impact areas are not adequate to assure that significant impacts are 
offset. Of specific concern is whether or not suitable relocation sites are 
available or can be recreated. Also, it will be necessary to incorporate 
management measures into any mitigation plan for these species to assure that 
suitable conditions are maintained at mitigation sites and relocation sites to 
assure that the species can become established and maintain themselves. This 
includes a predator-control program to assure that bullfrogs and predatory 
fish are excluded from mitigation sites. 

In the case of the tiger salamander, we are concerned that specific 
mitigation plans be provided. The DEIR indicates that culverts and fencing 
will be used to provide passage between denning sites and breeding habitat 
separated by Vasco Road. The document should provide evidence that such 



5^2 



Mr. John S. Gregg 
June 1, 1992 
Page Three 

mitigation is effective and feasible. It may be more effective to construct 
new breeding habitat in proximity to the denning habitat isolated by road 
construction. A more detailed discussion of this issue is needed in the DEIR. 

While the inundation zone of the reservoir will not affect the Alameda 
whipsnake, the document does not provide an adequate discussion of potential 
impacts associated with utility relocations, proposed recreational facilities, ^'^ 
and fire management activities. Potential negative effects to this species, 
as well as measures to avoid or offset impacts should be included in the 
document . 

In the discussion of impacts associated with the desalinization 
alternative, the document identifies the State-listed rare Mason's lilaeopsis 
and threatened California black rail as potentially being affected. The 
document provides no information on whether surveys were conducted to 
determine if these species would be affected by the project. The brine 
discharge pipeline would traverse brackish marsh bordering Suisun Bay which is 
suitable habitat for these species. Potential impacts and mitigation measures 
should be discussed in the DEIR. 

We appreciate the opportunity to provide these comments. Comments 
concerning impacts associated with the diversion points and on fisheries will 
be provided in a separate letter. Questions concerning our comments should 
be directed to Carl Wilcox, Environmental Services Supervisor, 707-944-5525. 

Sincerely 




Brian Hunter 
Regional Manager 
Region 3 



cc: Ms. Laurie Simmons/Mr. Mark Littlefield 
U. S. Fish and Wildlife Service 

Mr. Tom Coe, Corps of Engineer 

National Marine Fisheries Service 

Environmental Protection Agency 



6-9 



5-83 



Response to Comments from the California Department of Fish and Game - Region 3 

6-1 . Comment noted. CCWD appreciates the excellent working relationship it has developed with the 

California Department of Fish and Ganne and the willingness of the department to provide early 
input and comment in the environmental documentation process for the Los Vaqueros Project. 

6-2. Comment noted. 

6-3. Comment noted. The conceptual recreation plan contains substantive provisions to minimize 

impacts on wildlife species. The provisions are included in Section A-2 of the Stage 2 EIR/EIS 
Technical Report. The biological assessment, sent to the USFWS June 1, 1992. analyzes the 
effects of proposed recreational facilities on the San Joaquin kit fox and other wildlife species and 
includes an analysis of the effects of habitat fragmentation resulting from the reservoir and 
associated recreation facilities, specifteally on the southwestem shore of the Los Vaqueros 
Reservoir. The biological opinion is summarized in Chapter 20, "Consultation and Coordination". 
CCWD also expects to enter into an agreement with DFG, whteh will provkJe for minimization of 
arxj compensation for all kit fox impacts, in accordance with Fish and Game Code Section 2081 . 

6-4. The btological assessment Includes a detailed analysis of the effects on kit fox from direct habitat 

loss, habitat fragmentation, increased mortality, and reduction in adjacent habitat quality from the 
relocated Vasco Road. CCWD has agreed to purchase approximately 1.000 acres of mitigation 
lands outskJe the Kellogg Creek watershed, including lands in the Herdlyn watershed area to 
compensate for habitat loss along relocated Vasco Road. 

6-5. Comment noted. Specific mitigation plans for these resources are included as appendices to the 

final Stage 2 EIR/EIS. 

6-6. CCWD intends to fully mitigate project impacts on Califomia red-legged frogs. California tiger 

salamanders, and western pond turtles. The biological assessment contains an analysis of these 
three species with measures designed to avoid, minimize, and comp>ensate for impacts. In 
addition to the biological assessment, CCWD has prepared a mitigation plan that includes specific 
relocatk>n sites (both existing and created) and management plans that incorporate the indivkJual 
species needs for water, vegetation, upland habitat, and a predator-free environment. 

6-7. The issue of culverts, fencing, and replacement habitat for California tiger salamanders is 

addressed in the biological assessment. Mitigation for tiger salamanders along relocated Vasco 
Road will be combined with pond creation, enhancement, and undercrossings, with some type of 
structure to direct salamanders away from the road and to the undercrossings. CCWD has 
consulted with John Brode of the Califomia Department of Fish and Game to design a suitable 
"fencing-type" design to direct salamanders to culverts. If implementation of this measure is 
impractk:al, CCWD will conskjer constructing new breeding habitat in consultation with Mr. Brode. 
See response to comment 6-6. 

6-8. The bktiogical assessnr>ent analyzes impacts on the Alameda whipsnake from the proposed 

project, including recreational and fire management activities. All utility relocation alignments are 
outside Alameda whipsnake habitat. The biological assessment and Stage 2 EIR/EIS include 
measures to ensure that recreational impacts and fire management activities do not adversely 
affect the Alameda whipsnake. 

6-9. Comment noted. Surveys were conducted for Califomia black and clapper rails during May 1991 

in the brackish marsh bordering Suisun Bay. Although no rails responded to the taped calls, the 
brackish marsh is conskJered suitable habitat for Califomia black rails based on records of nearby 
occurrences. Impacts are presented in the Stage 2 EIR/EIS on pages 8-36 and 8-38, and 
mitigation measures are presented on page 8-46. 



Response to Comments of the Califomia Department of Fish and Game - Region 3 

5-84 



SENT BY:DWR CONSTRUCTION OFFIC; 



StoM af Callfornki 



5-12-92 



31PM 



91 66530993-) 



Memorandum 

o«- = ||AY1119» 

To : A-38 

Carol Whiteside 
Assistant Secretary 
Intergovernmental Relations 
The Resources Agency 
1416 Ninth Street 
Sacramento, California 95814 
From I D*portin«nt of Wotof tM«wrcM 



LETTER NO. 7 

Th« Rateurcoi Agoncy 



CC- 






V*i^: Comments on DEIR/DEIS, Los Vaqueros Project Stage 2 SCH 91063072 



The DEIR/DEIS does identify many of the complex Delta fisheries 
issues interrelated to the Central Valley Project, State Water 
Project and Contra Costa Water District. The major parameters that 
are commonly studied in connection with these fisheries issues are 
presented and evaluated. However, no information was found on: 

a. The present total number of fish impacted at the 
unscreened CCWD Delta diversion at Roc)c Slough. 

b. The projected numbers of fish impacted for the added 
diversions at Rock Slough or the proposed new intalce 
for Los Va<jueros . 

Various productive ideas about participation in ongoing 
mitigation activities were discussed. Our review was unable to 
identify a specific commitment to a mitigation plan. Independent of 
other mitigation activities, CCWD should show a mitigation program 
for direct impacts at the present and future Delta intakes . 

An important and urgent aspect of mitigation involves winter-run 
salmon, and potentially Delta smelt. Monitoring and identification 
of specific impacts to these fish should be identified with 
reasonable and prudent alternatives. 



7-1 



Lanf! anri Right xif-Wwy 

It appears that the DEIR/DEIS does A9t,.,dlscu8s the coordination 
necessary related to ali^jwitWit- '6£''the' Lcf^' vaqueros Project preferred 
alternative intake location on Old River and alternative locations of 
the enlarged SWP Clifton Court Forebay outlined in the South Delta 
water Management Program DEIR/AEIS released by the Department of 
Water Resources in June 1990. The Los vaqueros DEIR/DEIS should 
state that such coordinatlo(\^^a^, t^^)l6ep:plapey' and will continue, 
between the CCWD and DWR. " • . " .. 

»vCriAi.. ' '. RECEIVED 



7-2 



5-85 



MAY 1 2 1992 



SENT by: DWR CONSTRUCTION OFFIC; 5-12-92 2:31PM; 9166530993- 7981452; « 



Carol Whiteside 

MAY 1 1 1992 
Page Two 



SflfPl-v nf Dams 

Los Vaqueros Dam and its alternative Kellogg Dam fall under the 
jurisdiction of DWR' s Division of Safety of Dams. The applicant must 
secure an approved application from this Division prior to 
commencement of construction. The Division will supervise the 
construction of the dam and, upon satisfactory completion, will issue 
a Certificate of Approval to impound water. 

The DEIR/DEIS includes a general, but clear statement that 
covers the Division's review and approval prior to start of 
construction. The general description provided in the DEIR/DEIS for 
the proposed project is adequate. Detailed design features will be 
addressed and resolved in our review of the construction plans and 
specifications for Los Vaqueros Dam as part of our application 
process . 

nfltfl Mnriftllng 

1. It is difficult to understand what operation studies are applied , 
to a given alternative. This should be made more clear. A l 
table showing which operation studies were used for each 
alternative would be useful. 



Page 3-7. Fischer Delta Model results for flow in the Delta 
Cross Channel, Georgians Slough, and the San Joaqfuin River at 
Twitchell Island are used to evaluate flow conditions in the 
Delta. 



I 
I 

Our flow-split analysis shows that FDM consistently predicts 
higher cross transfer flow compared to the standard flow tI 
split relation determined by multiple tidal cycle flow " 

measurements. FDM output have a higher intercept and larger 
slope resulting In predictions of cross transfer flow 500 to 
1000 cfs greater than the accepted relation. To the extent 
that FDM over predicts cross transfer flow, it also implies 
that too much carriage water is released because reverse flow 
will be reduced by a like amount. 



Net flow at Twitchell island is not obtained directly from FDM. 
Instead, it is calculated by subtracting simulated net flow 
through Threemile Slough from simulated net flow at Jersey Point. 
The resulting net flow is used to assess impacts on fisheries. 
Why the analysis does not simply use the simulated net flow from 
San Joaquin River at Twitchell island is not clear. 



5-86 



I 
I 
I 
i 
I 
i 



SENT BY:DIUR construction OFFIC; 5-12-92 2:32PM ; 9166530993^ 

'^981452;h 4 



Carol Whiteside 
Page Three 

3. Page 5-9. Impact Screening Criteria #2: At D-1485 water quality 
stations, FDM model results are flagged when base salinity 
results are greater than 95 percent of the D-1485 standard, and 
the alternative causes any increase in salinity levels. 
The purpose of this approach is to screen water quality changes 
caused by the project that could impact standards. However, this 
is not an incremental use of the model. The 95 percent criteria 
is determined by the model in the first place. This suggests 7.7 
that the model is very accurate in an absolute sense (rather than 
incremental) and can predict conditions under which small 
differences from the standard occur. 

The approach implies that impacts on water quality below 

95 percent of the standard are not significant, which may not 

be the case. 

1. It appears that Los Vaqueros Reservoir was not actually modeled 
in the DWRSIM planning simulation model. Instead, results from 
three DWRSIM studies are presented to show three different 
levels of future development, all of which include a fixed 
CCWD Delta diversion. This fixed CCWD diversion appears to 
include water for Los Vaqueros although that is not clearly 
stated in the study assumptions (Technical Report, Section B- 
2) . The assumptions should clarify what operation is assumed 
in the CCWD diversion amounts listed (is Los Vaqueros 
operation included or not?) . 



7-8 



To properly evaluate impacts of Los Vaqueros Reservoir on the CVP 
and SWP systems, each of the three DWRSIM studies (A7, 543 and 
476) should have been simulated twice; first without Los Vaqueros 
Reservoir in operation and second with Los Vaqueros added. The 
impacts on SWP and CVP operations can only be correctly modeled 
and evaluated using this Incremental approach. Thus we recommend 
that the DEIR contain DWRSIM study results from both '*with" and 
'^without" Los Vaqueros scenarios at each of the three levels of 
development (a total of six DWRSIM studies) . 

The DEIR/DEIS section on project operations (page 2-5) states 
that water could be diverted from the Delta to fill Los Vaqueros 
storage between the months of November through June . we suggest 
that export pumping be curtailed to non-project levels in the 
months of May and June, in order to comply with SWRCB D-1485 
criteria for striped bass survival. According to D-1485 
criteria, total CVP and SWP Delta diversions are limited to a 
combined total of 6,000 cfs in the months of May and June. Thus, 
any increase in Delta exports above these existing limits would 
appear to aggravate the impacts on striped bass. 



5-87 



7-9 



SENT BV:DUR CONSTRUCTION CPIC; 5-X2-92 2:33PM; . ,,,5530993. 7961.52; « c 



Carol Whiteside 

fixr il i^ 

Page Four 



In the DEIR/DEIS Technical Report (page B-31), the title for 
Section B should clearly state that the following Section B 
assumptions are for CCWD'e simulations using the DWRSIM model 
The title on page b-31 gives a false impression that the 7.10 
following studies were run by DWR, which is not the case. A 
better title might be: "CCWD Planning Simulation Model 
Assumptions For Los Vaqueros Project Studies Using The DWRSIM 
Model". 



r.a. bfc:^^ 

Edward F. Huntley, Chief 
Division of Planning 
CALNET 453-1099 



5-88 



I 
I 

I 
I 
I 
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9 



Responses to Comments of the California Department of Water Resources 



7-1. As a result of comments received on the draft EIR/EIS and meetings with the various resource 

agencies. CCWD and Reclamation have developed mitigation measures that not only reduce 
Impacts to Delta resources, but actually improve conditions as compared to no project, particulariy 
for winter-mn chinook salmon. These measures consist of revisions to the proposed project 
operations in terms of the timing and magnitude of diversions from the Delta. Under the proposed 
mitigation plan, CCWD will use a portion of the water stored in the Los Vaqueros Reservoir in lieu 
of direct diversions from the Delta during the winter-run chinook salmon's season of vulnerability 
This operatk>n will allow CCWD to eliminate si\ diversions from the Delta, including those from Its 
existing Intake at Rock Slough, for a total of approximately 30 calendar days between March 15 
and May 15 of each year. In addition, CCWD wyi generally not fill the Los Vaqueros Resen/oir 
between March 15 and May 31. 

The revised project operations are fully described In the bkjiogical assessment for the proposed 
project as are the effects of the revised operattons on special-status fish species. The mitigated 
operatk>ns are also described in Chapter 4 of the final Stage 2 EIR/EIS, along with a discussion 
of effects on other fish species. 

7-2. CCWD and the Califomia Department of Water Resources (DWR) have coordinated extensively 

regarding the location of proposed DWR and CCWD facMities. CCWD believes that the two 
agencies have developed a good working relationship and intends to continue coordination efforts 
in the future as necessary. 

7-3. Comment noted. CCWD recognizes DWR's responsibilities relating to safety of dams and has 

coordinated extensively with staff of DWR's Division of Safety of Dams to submit the necessary 
docunr>entatkDn to DWR's Division of Safety of Dams as project planning proceeds. 

7-4. A descriptton of how modeling was conducted for the Los Vaqueros Project is included on pages 

1-10 through 1-12 of the EIR/EIS. This discussion includes a description of which DWRSIM model 
runs were used to analyze the alternatives under existing, future, and future cumulative conditions. 
It is important to note that CCWD used the same DWRSIM model runs to analyze the alternatives 
under each condition. Only CCWD demands under the various alternatives were changed. 

7-5. The comment assumes that the accepted flow split relation accurately represents measured flow 

data. The relationships are described in DWR's DAYFLOW documentation (February 1986, pages 
17-19). The relationships were developed in 1978 (page 18) but were based only on 
measurements made prior to the time State Water Project exports began (DWR, "Bkjlogical 
Assessment, Effects of Central Valley Project and State Water Project Delta Operations on Winter- 
Run Chinook Salmon", October 1992, pages 47-48). Measurements made by DWR after 1970, 
whfch show significantly higher flows, were not Included in the analysis. The DWR relationships 
Indteate that for a range of flows, partially dosing the cross-channel will increase flow through the 
two channels: this is counter-intuitive and contradicted by field measurements. 

In 1982, the late Professor Hugo B. Fischer of the University of Califomia perfomied an 
independent analysis of all the data and found relationships that yield higher estimates of the 
cross-transfer flow than DWR's relattonships. 

The figures presented at the end of responses to comments of DWR show the measured data and 
results from the Fischer Delta Model (FDM). The FDM data were generated using the 19-year 
mean tWe. The figures Include flow measurements made by DWR in 1990 which again are higher 
than the data used in the DWR's 1978 analysis. 



Responses to Comnmrts of the Califomia Department of Water Resources 

5-89 



The figures show DWR's relationship Is inconsistent with recent measurements. The FDM provides 
an appropriate representation of the measured data. 

7-6. The methodology used provides the flow in the San Joaquin River past Twitchell Island plus the 

flow through False River. This provides a better estimate of the flows important for the fisheries 
impact analysis than simply the flow past Twitchell Island. The same result can be obtained by 
directly adding the modeled flow past Twitchell Island with the nrHxieled flow through False River. 

7-7. The approach used to analyze water queility impacts in the EIR/EIS does not indicate that impacts 

on water quality below 95% of D-1485 standards are less than significant. All potential impacts 
wtien salinity is below 95% of D-1485 standards are flagged by criterion l. 

Criterion 1 flags all changes greater than 5% of the base If the changes are also greater than 5 
mg/l chloride or 20 micromhos per centimeters electrical cortductance. Criterion 1 alone would 
indicate that some increases in salinity that approach or exceed D-1485 standards are not 
significant. Criterion 2 was developed so that the latter cases would be ir>duded in the ar^ysis 
as well. The 95% level is derived from the 5% accuracy limit used In criterion 1. 

In summary, when the modeled salinity was less than 95% of a standard, it was flagged if the 
change was at least 5% (and greater than 5 mg/l or 20 ^mhos/cm); if it was greater than 95% of 
a standard, any increase was flagged. 

7-8. The l_os Vaqueros Project was modeled with the DWRSIM planning simulation model. Model 

simulations included cases with and without the project alternatives. Results are summarized in 
the Stage 2 EIR/EIS Technical Report, Section B-1 , where the tables show results with and without 
project alternatives and the differences resulting from the alternatives. Additional information 
regarding the effects of CCWD's revised operations are included in the biological assessment and 
in Attachment 2 to the final EIR/EIS. 

The future cumulative case was not run with the project for the reasons discussed in Chapters 3 
and 5 of the ElR/ElS. The uncertainty in the North and South Delta Management Program 
alternatives, as well as the Los Bancs Grandes project, do not allow a detailed analysis of that 
case. The approximate analysis performed is the appropriate level of detail considering the 
uncertainty in the configuration on many of these possible projects. 

7-9. See response to comment 7-1. 

7-10. Comment noted. However, it should be noted that, although CCWD ran these simulation studies 
again, the only minor change made was to alter CCWD's demands. Therefore, the assumptions 
described in Section 8-2 accurately reflect the assumptions originally included in the referenced 
DWRSIM model runs. 



Responses to Comments ol the California Department of Water Reaounses 

5-90 



Delta Cross-Channel Flow 
Measured and Fischer Model 



£5- 

o 

c 
<s 

S4- 

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is- 

U- 

c 




• 






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\- 










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61 - 
0- 




— r- I 


: 1 


1 I 1 1 I 


— \ \ 1 



5 6 7 8 9 10 11 12 13 14 15 16 

Sacramento River Flow (thousand cfs) 
+ 1950-71 Measured + FDM V8 DWR • Post 71 Measured 

Georgiana Slough Flow 
Measured and Fischer Model 



3500 




7 fl 9 10 11 12 13 

Sacramento River Flow (thousand cfs) 

♦ 1950-71 Measured + FDM V8 '— DWR 



Post 71 Measured 



Cross Channel Open 



5-91 



LETTER NO. 8 



Contra 

Costa 

County 



t^ \3>.^ 



^ . J> 



Public Works Department 

255 Glacier Dnve 

Martinez, Califoma 94553 4897 

FAX: (510) 313 2333 

Telephone: (510) 313-2000 

May 12. 1992 



J Michael Walford 
Public Works Director 

Milton F. Kubicek 
Deputy Dree tor 

Maunce E. Mitchell 
Deputy Drector 



John Gregg 
Program Manager 
Contra Costa Water District 
P.O. Box 4121 
Concord, CA 94525 



RE: Draft Stage 2 Environmental Impact Report for Los Vaqueros 



Dear Mr. Gregg: 

The Public Works Department has reviewed the Draft Stage 2 Environmental Impact 
Report for the Los Vaqueros Project and has the following comments: 

1 . Section A-3 of the Technical Report, entitled Detailed Construction Information, 
describes the transport of construction materials and heavy equipment to and from 
Los Vaqueros Reservoir, the transfer reservoir, and the transfer reservoir pumping 
plant. Please include a discussion of the impacts these transport trucks will have 
on the structural pavement section of roads in Contra Costa County, that will be 
used for transport, over the two to three year construction period. Also, include 
a discussion of the mitigations needed, such as pavement repair and maintenance, 
for construction truck impacts on these roads. 

2. The average daily truck traffic described in the Technical Report should also be 
discussed and presented in Chapter 1 3 of the DEIR. Truck traffic generation and 
distribution should be displayed in figures. The offsite sources of construction 
material, along with their associated transport routes, should also be displayed in 
figures. 

3. The impacts and mitigations of recreational traffic should be discussed in Chapter 
13 of this DEIR. 



If you have any questions regarding these comments, please contact me at (510) 
313-2382. 

Very truly yours, 



LT:TR peo 
c:Gregg.t6 

cc: M. Shiu, Road Engineering 



5-92 




Lowell Tunison 



PECI^IVED 



Senior Civil Engineer ^av i o mnn 
Major Projects ^^^ ^ ^ ^^S? 



Maintenance Division: 2475 Waterbird Way • Martinez. California 94553-4897 • Telephone: (510) 313-7000 • FAX: (510) 313-7014 1 



Response to Comments of the Contra Costa County Public Works Department 



8-1. Chapter 16 of the EIR/EIS, "Public Services", includes discussion of project-related truck traffic 

effects on local roadways and recommends mitigation measures for significant impacts 
Discussions of these items are found on pages 16-10 and 16-16 through 16-19. 

8-2. Because of the large size of the project area and the number of local, regional, and institutional 

issues related to the project, CCWD, its consultants, and Reclamation spent considerable effort 
attempting to maintain NEPA recommendations on the size of the document. This effort included 
moving much of the background and technical information, including the information requested 
in this comment, from the EIR/EIS into the technical report. 

8-3. Chapter 13, Transportation", discusses the impacts of recreation traffic on level of sen/ice and 

traffic volumes. The effects of recreation plan traffic on the maintenance of local roadways did not 
meet the significance criteria outlined on page 16-9 and therefore were found to be less than 
significant. 



Responses to Comments of the Contra Costa County Public Mtortts Pepartment 

5-93 






EAST BAY 
MUNICIPAL UTILITY DISTRICT 



May 13, 1992 



LETTER NO. 9 

JORGE CABRASCO 

C£N£RAL MANACtR 

CC 



Mr. William J. Woska 
Acting General Manager 
Contra Costa Water District 
P.O. Box H20 
Concord, CA 94524 

Dear Ifer^WOSRa: 

At a workshop on April 21, EBMUD's Board of Directors selected 
six composite programs for detailed evaluation in the EIS/EIR for 
the District's Water Supply Management Program (WSMP) . None of 
the selected programs include a joint CCWD/EBMUD Los Vaqueros 
project. In selecting the six primary composite programs, the 
Board concluded that there are alternatives available to EBMUD 
that are preferable to Los Vaqueros participation with respect to 
cost, water quality and environmental impacts. Although it was 
recognized that a substantial delay in implementation of the Los 
Vaqueros Project would occur if it became a joint CCWD/EBMUD 
project, this was not a primary factor in the decision. 

The analyses of potential joint projects completed to date will 
be reflected in the District's Draft EIS/EIR, scheduled for 
release in November 1992 . 

EBMUD staff have reviewed CCWD's Draft Stage 2 EIS/EIR for the 
Los Vaqueros Project. In reviewing this document, one EBMUD- 
related issue that should be addressed in the final Los Vaqueros 
EIS/EIR was identified: In discussing a possible connection to 
EBMUD's water supply, the Los Vaqueros Draft EIS/EIR indicates 
that EBMUD's Mokelumne Aqueducts are vulnerable to seismic 
damage. It should be noted that the EBMUD Board of Directors has 
decided to strengthen the Mokelumne Aqueducts against earthquakes 
and Delta flooding as part of the WSMP. 

We appreciate your assistance in providing us with information 
required to evaluate the joint Los Vaqueros project. If you have 
any questions, please contact John Lampe, Manager of Water 
Planning, at 287-1127. 

Sincerely, 






M 



9-1 



4^^ 



Jbrge Carrasco 



cc: EBMUD Board of Directors 

i/John S. Gregg, Program Manager, Los Vaqueros Project 



JC:MKG:tl 

37S ELEVENTH STREET . OAKLAND . CA 9*607 4240 . ISWI 287 0W1 

BOARD Of DIRECTOPIS NANCY J NADEt . KENNETH H SIMK40NS . ANDREW COHEN 

JOHN A COLEMAN . STUART fLASHMAN . JOHN M GIOIA . KATHERINE McKENNEY 






LOSVAO 05/07/92 



5-94 



Response to Comments of the East Bay Municipal Utility District 



9-1 . Comment noted. CCWD is aware of East Bay Municipal Utility District's decision to strengthen the 

Mokelumne Aqueduct. The aqueduct would, however, remain substantially more vulnerable to 
damage than the Los Vaqueros Reservoir. In addition, it remains unlikely that the East Bay 
Municipal Utility District could provide sufficient water to meet CCWD's emergency supply needs. 



Responses to Comments of the East Bay Municipal Utility District 

5-95 



^ 



Delta Diablo Sanitation District 



OFFICE AND TREATMENT PLANT 2500 PITTSBURG-ANTIOCH HIGHWAY: ANTIOCH, CA 94509 
rrtO i'^^'i ADMIN FAX: (415) 77&^13 TELEPHONE (415) 778-»040 MAINT. FAX: (415) 778-8565 



LETTER NO. 10 



May 4, 1992 



Mr. John S. Gregg 

Program Manager, Lob Vaqueros Project 

Contra Costa Hater District 

P. O. Box 4121 

Concord, CA 94524 

SUBJECT: LOS VAQUEROS PROJECT, DRAFT STAGE 2 ENVIRONMENTAL IMPACT 
REPORT/ENVIRONMENTAL IMPACT STATEMENT 

Dear Mr. Gregg: 

Delta Diablo Sanitation District provides water and wastewater 
Banagement , engineering, and operational services to the citizens of Discovery 
Bay. He have reviewed the Draft Stage EIR/EIS for the subject project and 
note the reference on page 5-34 to the potential impact of Discovery Bay's 
treated wastewater discharge on the Rock Slough/Old River Mo. 5 supplemental 
IntaJce. He understand that the Hater District is currently studying 
mitigation measures and is developing several alternatives, including the 
relocation of the effluent discharge. 

It is our position that any mitigation measures would be the sole 
responsibility of the Hater District and should have no economic impact on the 
ratepayers of Discovery Bay. 

Very truly yours. 



lO-I 



'UA^U ^y^ 



Ronald A. Tsugo/ca 

General Manager/District Engineer 



RAT: dew 



cc: Tom Torlakson, Supervisor, District 5 

Ed Cornell, Chair, Citizens' Advisory Committee 

Joe Philbrick, President, Discovery Bay Municipal Advisory Committee 



MAY -7 1992 

5-96 

A political subdivision ol the State of California Provides Wastewater Treatment services to tine citizens of Antiocti, Pittsburg, and West Pittsburg 



I 



Response to Comments of the Delta Diablo Sanitation District 



10-1. Comment noted. CCWD concurs that it would bear financial and other responsibility for such 
mitigation, if it is needed. 



Response to Comments of the Delta Diablo Sanitation District 

5-9T 



NAY- 1 2-92. TUF 14:05 



CITY OF LIVERMORE 



FAX NO. 4153735131 LETTER NO. 11 






May 12, 1992 



John S. Gregg 
Program Manager 
Los Vaqueros Project 
P.O. Box 4121 
Concord, CA 94524 



ADMINISTRATION BUILDING 

1052 South Livermore Avenue 

Llvormore, CA 94550 

(510)373-6200 



CC- 







SUBJECT: LOS VAQUEROS STAGE 2 EIR/EIS 



Dear Mr. Gregg, 

The City of Livermore has the following comments on the Draft EIR/EIS for the Los 
Vaqueros Reservoir Project regarding transportation impacts. 

The EIR/EIS evaluates traffic Impacts for the year 1995 and the year 2025. The 
document correctly points out that the level of service on Vasco Road (existing 
and relocated) as a two-lane facility Is unacceptable. However, adding addition- 
al traffic to an already unacceptable situation compounds the problem and must be 
recognized and addressed. While it is not CCWD's responsibility to resolve 
regional transportation problems, k'^^r^ effort should be made to address the 
incremental Impacts from the proposed project. 

Construction Impacts. The additional traffic from construction may be minimal 
when compared to existing peak-hour volumes; however, the use of Vasco Road 
(existing and relocated) by heavy construction equipment can cause additional 
delays and potential hazards. An additional mitigation measure should be 
included which restricts the movement of heavy construction equipment on Vasco 
Road to non-peak hour times. 

Operation Impacts. The EIR/EIS states that the draft recreation plan associated 
with the reservoir could generate a peak day-use of up to 9,500 people and up to 
1.8 million people per year. While the EIR/EIS states that Vasco Road as a four- 
lane facility would operate at an acceptable level of service, with or without 
the project, no analysis is provided to support this statement. 

Future traffic impacts are evaluated for the year 1995 and the year 2025. An 
evaluation of potential Impacts far beyond the planning horizon of most jurisdic- 
tions is highly speculative. While It is acknowledge that the full build-out of 
the recreational facilities may not occur until 2025, an evaluation of potential 
traffic Impacts for the year 2010 assuming full build-out should be provided. 

RECEIVED 
MAY 1 2 1992 



5-98 



J 



I 
I 

\ 
I 



< 



I 



MAY-12--92.TUE 14:06 CITY OF LIVERHORE FAX NO. 4153735135 



P. 03 



If you have any questions regarding this matter, please contact me at (510) 373- 
5200. 

Respectfully, 

Susan M. Frost 
Associate Planner 

CC: Bob Brown, Planning Director 



5-99 



Response to Comment of the City of Uvermore 



11-1. The analysis included in the Stage 2 EIR/EIS and the Vasco Road and Utility Relocation Project 
EIR Indicates that the current and projected future level of sen/ice on txjth the existing and 
relocated Vasco Road is unacceptable. Implementation of the recreation plan is the only 
comportent of the Los Vaqueros Project that would contribute to traffic volumes on Vasco Road. 
The Stage 2 EIR/EIS recognizes that even these minor contributions to a roadway with 
unacceptable levels of service would be a significant impact. These impacts and measures to 
reduce these impacts to less-than-significant levels are described in Chapter 13, Transportation" 
(see pages 13-26 and 13-31). 

11-2. As described on page 13-22 of the EIR/EIS, the additional traffic volumes created by construction 
of tf>e Los Vaqueros dam and reservoir would generally consist of truck traffic, would not affect 
the level of service on area roadways, and would be weJI within the Initial screening criteria for 
impacts developed by the Institute of Transportation Engineers, described on page 13-13 of the 
draft Stage 2 EIR/EIS. Therefore, no impacts are expected arKJ no mitigation measures are 
required. However, to further reduce the impact of project construction-related traffic, mitigation 
measure 13-1 has been included in the list of environmental commitments. See Cliapter 19, 
"Impact Conclusions and Environmental Commitments". 

11-3. Cliapters 4.10 and 8 of the Vasco Road and Utility Relocation Project EIR, which is incorporated 
by reference into the Stage 2 EIR/EIS, contains substantial analysis of the local roadway network 
and provides supporting documentation regarding the ability of a four-lane Vasco Road to provide 
acceptable levels of service (pages 4.10-59 and 8-25 of the Vasco Road and Utility Relocation 
Project EIR). The additional traffic added as a result of increased recreation in the Kellogg Creek 
watershed would occur primarily in off-peak periods and would therefore not meet significance 
criteria identified in the Stage 2 EIR/EIS. 

11-4. CCWD believes that the analysis conducted for the proposed project is appropriate. There is no 
indication tfiat all recreation facilities will be developed by 2010. In addition, impacts of 
recreatiorul facilities were identified as less than significant b>ecause traffic volumes associated with 
the recreation facilities did not meet significance criteria. Changing the analysis as suggested by 
this comment would not affect whether the significance criteria are exceeded. 



Response to Comments of the City of Uvemwre 

5-100 



LETTER NO. 12 

RECLAMATION DISTRICT No. 800 

AND DISCOVERY BAY RECLAMATION AND 
DRAINAGE MAINTENANCE DISTRICT 

P.O. BOX 1461, STOCKTON, CA 95201 ' 

^l^ 13. 2. ^,.5 May 11, 1992 (.1,.,, 



Mr. John Gregg 

Contra Costa Water District 

P. O. Box H20 

Concord, California 94524 

Re: Los Vaqueros Project 

Draft Environmental Impact Report/ 
Environmental Impact Statement - February, 1992 

Dear Mr. Gregg: 

Reclamation District No. 800 (RD 800) , which includes 
the Discovery Bay Development, has a niimljer of concerns 
related to the impacts of the proposed Los Vaqueros project. 

The areas west of Old River that would be inundated by 
a Los Vaqueros Dam failure, may not be correctly shown. RD 
800 maintains a levee along its western boundary, as shown 
on the attached map. This levee is equal in height to the 
levee that borders RD 800 along Old River. The dam break 
model indicates that the Old River levee would not be 
overtopped; therefore it is questionable as to whether the 
western levee should be overtopped. This western levee 
which protects the homes and improvements in a portion of 12-1 
the Discovery Bay Development as well as the agricultural 
area of RD 800, should be included and appropriately studied 
in the dam break model. The potential flooding of major 
urban areas such as Discovery Bay in the event of dam 
failure is a significant impact which merits careful analy- 
sis and mitigation. Future development planned for the area 
will greatly increase the negative impact. 

The location of the Old River No. 5 intake facility 
would be located very near the RD 800 's south pump station 
discharge. This pump station discharges agricultural 
drainage as well as treated wastewater from the Discovery 
Bay Development. The E . I .R. /E . I .S. states that placement of 
a municipal water supply near a treated sewage discharge 12-2 
would be a significant adverse impact (5-31) . If it becomes 
necessary to relocate any of RD 800 's facilities, it is 
expected that the responsibility and costs will be borne 
entirely by C.C.W.D. The mitigation of this impact should 
be thoroughly addressed. The Regional Water Quality Control 

RECEIVED 
^■'°' MAY 1 3 1992 



Mr. John Gregg 



-2- 



May 11, 1992 



Board has required that the treated wastewater be discharged 
to Old River and that such waters not be discharged to 
Indian Slough. The limited flushing action within the tidal 
bays of Discovery Bay is a major factor. 

At Old River at Highway 4, several instances were cited 
where a degradation of water quality would occur with the 
proposed project. We are concerned about the possible 
impact on water quality within the tidal bays of Discovery 
Bay. This potential impact did not appear to be addressed. 

The Old River No. 1, 2, 5 and 6 intake facilities will 
have a significant impact on RD 800 's flood control levee 
along Old River. RD 800 will require that a permit be 
acquired for any construction on, over, under or along the 
levee or drainage facilities. It is absolutely imperative 
that RD 800 's rights and ability for the maintenance and 
operation of their reclamation works not be adversely 
impacted. Included in RD 800 's reclamation works is the 
main drainage canal running north and south and partially 
east and west through the District. It is very important 
that the long-term operation and maintenance of the canals 
be considered in the design of the crossings. 

Portions of the RD 800 levee along Old River have been 
experiencing undercutting and increased seepage due to 
scouring action. The scouring action appears to be related 
to export pumping by the CVP and SWF. The location of your 
intake south of Indian Slough would appear to aggravate an 
already critical situation. It appears that this potential 
impact was not considered in the E.I.R. For the same 
reasons that the SWF is seeking to relocate their intake 
farther north, you should perhaps give greater consideration 
to your more northerly locations such as Old River No. 3. 

Yours very truly. 




DANTE JOHN NOMELLINI 
Secretary and Counsel 



DJN: ju 
Enclosures 
cc: Trustees 

Chris Neudeck 



12-^ 



5-102 




LEGEND: 



District Levee 



' r I' Kj-y 

t \ij \^ 

RECLAMATKHi DISTRICT NO. 800 
BYRON TRACT 

DISTRICT LEVEE 



5-6-92 
Not to scale 



5-103 



Response to Comments of Reclamation District No. 800 and Discovery Bay Reclamation and Drainage 
Maintenance District 



12-1. As the EIR/EIS discussed, the Impact of flooding in the event of dam failure is considered to be 
less than significant tiecause the protiability of occurrence is extremely low. Nevertheless, dam 
failure Inundation studies were conducted to examine worst-case scenarios to provide a 
conservative basis for emergency evacuation planning. While the effects of the levee along 
Reclamation District (RD) 800's western boundary were not specifically simulated In this 
assessn>ent, examination of the peai< wave height, wave velocity, energy dissipation, and minor 
seepage losses indicate the described dam failure wave is likely to rapidly overtop and erode this 
western levee. Although the levee along the western boundary of RD 800 has approximately the 
same elevation (+13 msl) as the levee that borders RD 800 along Old River, these two levees are 
not of equal height. The land surface elevation at the toe of the levee along Old River is lower. 
Therefore, a much larger volume of water could be contained behind the Old River levee. 

12-2. Comment noted. Any costs and permitting actions required to relocate the referenced drainage 
discharge as a direct result of drinl<ing water standards applicable to CCWD's Old River intake 
facility will be the responsibility of CCWD. 

12-3. The water quality Issues discussed in the Stage 2 EIR/EIS relate to relatively minor changes in 
salinity at several Delta locations (generally less than 5 mg/l chloride). These minor changes in 
salinity would not alter the beneficial uses of waters within Discovery Bay. 

12-4. Comment r>oted. CCWD recognizes the need to obtain a permit for construction activities at 
levees and has submitted to Reclamation District 800 a draft permit agreement outlining 
maintenar>c€ and operation responsibilities for the Reclamation facilities affected by the Los 
Vaqueros Project. CCWD will continue to work with the Reclamation District to ensure tfiat the 
ability of Reclamation District 800 to meet its responsibilities is not impaired as a result of the Los 
Vaqueros Project. 

12-5. During development of the Los Vaqueros Project, CCWD used a model to assess flow patterns 
in Okj River. The model results show that flows in Old River range from about 2,000 to 6,000 cfs 
in the north, and 9,000 to 14,000 cfs to the south. These variations are caused by tidal action and 
pumping at the State Water Project and Central Valley Project facilities. The flow discussed above 
would result in velocities of between 0.333 feet per second (fps) to 2.333 fps in Old River. The 250 
cfs CCWD diversions would add, at most, about 0.04 fps to these existing velocities. This 
contribution is very minor and would not affect undercutting of or increased seepage through 
levees aior>g Old River. 



Response to Comments of Reclamation District No 800 and Discovery Bay Reclamation and Drainage Maintenance District 

5-104 



LETTER NO 13 

"^ ns^i ^ SAN RAMON VALLEY 



%_0lO^.S' 



FIRE PROTECTION DISTRICT 



Administration 1500 Bollinger Conyon Road Fire Prevention 

ptKjoe: 510-838-6600 San Romon, California 94583 ^^o"®- 5io-838-668o 

Fax: 5 1 0-838-6629 Fax: 5 1 0-838-6696 

May 22. 1992 ^^ ^^^^ 

Mr. Gary W. Darling V^sljt 'ov^ 

Project Permits Manager i^\,,^ 
Ijos Vaqueros Project "^ 

P.O. Box 4121 UjV<\^ 
Concord, CA 95424 

Dear Mr. Darling: 

Our staff members have reviewed the Draft Stage 2 Environmental Impact Report/Statement for the Los 
Vaqueros Project dated February 1992. We are forwarding our comments regarding pages 16-6 and 16-7, 
which pertain specifically to the services provided by the San Ramon Valley Fire Protection District. 

The following items need correction and clarification: 

Page 16-6, last paragraph: The paragraph should read- SRFPD, which now includes the former 
Tassajara Fire Protection District, would provide first responses to the southwestern portion of the Kellogg 
Creek watershed, as outlined in the agreement of April 1989 with the Contra Costa County Water District. 
Two stations in this District are near the western edge of the watershed. Station 36, on Camino Tassajara 
Road has three engines, and two water tenders. The response time from this station is approximately 15- 
20 minutes. 

Page 16-7, second paragraph: The paragraph should read- Equipment at Morgan Temtory Road Station 
37, consists of two engines and water storage. This station operates on a volunteer basis, with variable 
response times depending on the availability of staff. 

Page 16-7, Relevant General Plan Policies: 7-81- These paragraphs should read- Wiidland fire 
prevention activities and programs such as controlled burning, fuel removal, establishment of fire roads, 
fuel breaks, and water supply, will be regional to reduce wiidland fire hazards. 

Ambulance Service: The Kellogg Creek Watershed area is served by the Regional Ambulance Company 
and the San Ramon Valley Fire Protection District. Regional ambulances are stationed at facilities in 
Livermore, Pleasanton, Dublin, Brentwood and Antioch. San Ramon Valley has four Basic Life Support 
ambulances, with two Paramedic staffed ambulance which could respond from the San Ramon Valley 
area. The District also utilizes helicopter ambulance services coordinated through the Incident Commander 
from the Engine Company at Station 37. 

Thank you for the opportunity to review this draft. If I can be of assistance, please do not hesitate to 
contact me. 

Respectfully, ^^ 




Assistant Chief, Operations 



13-1 



Richard Probert 5..,q5 



Response to Comment s of the San Ramon Valley Fire Protection District 

13-1. Comments noted. The final EIR/EIS has been modified to reflect these changes and these 
comments will be considered during ongoing planning for construction and operation of the Los 
Vaqueros Project. 



Response to Comments of tt)e San Ramon Valley Fire Projection District 

5-106 



MAY- 12- 1992 15:40 FROM CCC COMMUNITY DEVELOPMENT 



TO 



LETTER NO. 14 



The Board of Supervisors 

County Administration Building 
661 Pine St.. Room 106 
Martinez, California 94553-1290 

Tow Pow«fi, 1«i DIttflcl 
N*ncy C F«M«fi, fjv) DItinci 
Ro<M<1 1. SdmKttf, are Olstrlci 
tMMM WtIbM MePMk, 4lh District 
Tm TertAluM, Oh Diiirtei 



Contra 

Costa 

County 




PECEIVED 

MAY 1 2 1992 
LOS VAQUEROS 



Phit Balchetor 

Clerk 01 the (Joara 

County A<JnilnlMrslor 
(5101 t54fl.237) 



May 12, 1992 



Mr, Gary Darling 
Contra Costa Water District 
P.O. 80X4121 
Concord, CA 94524 

Dear Mr. Darling: 

Thank you for the opportunity to review the Draft Stage 2 Environmental Impact 
Report/Environmental Impact Statement for the Los Vaqueros Project. 

The County understands the need for this project as a source of higher quality water as well 
as a source of emergency water supply, and recognizes significant efforts on the part of the 
water district to obtain partnership or joint-use commitments from other agencies. However, 
the EIR/EIS Alternatives Analysis should have included a larger reservoir option. It is indeed 
unfortunate that other agencies did not take advantage of the opportunity to participate In this 
project. In particular, from the perspective of statewide water management, it would have 
been appropriate for local water agencies or the State Water Project to participate In this new 
water bank. The reservoir would have been more cost-effective and the impacts associated 
with additional storage capacity would have been minimal. Despite lack of agency interest 
during early stages of this project, it would have been prudent for the Water District to 
complete the environmental assessment for the larger reservoir in this document, as this now 
eliminates any possible joint use possibilities with the present schedule. Recognizing the 
importance of this project and the need for the project to go forward at this time, the County 
does not wish for this omission to delay the construction schedule or other aspects of this 
very important project. 

On Page 1-7 and Figure 13 the areas being considered to receive to Los Vaqueros Reservoir 
ere listed and shown. The map does not appear to be consistent with planning boundaries 
or spheres of influence for the Oakley or Antioch areas end needs revision. What are the 
implications for land areas which are outside these boundaries which developers wish to 
develop? What are the implications for water service to Brentwood In terms of use of the Los 
Vaqueros water supply? 

On Figure 2-2 the Old River Pipelines fiS and ^6 are shown located south of Discovery Bay. 
Their location appears to provide room for improvements which may be required in the future 



14-1 



14-2 



14-3 



5-107 



MftY-12-1992 15:41 FROM CCC COWUNITY DEUEL0PI1ENT TO 97981452 P. 03 

Mr. Gary Darling Data: May 12, 1992 

EIR/EIS -- Los Vaqueros -2- File: WA-3 



to State Route 4 as discussed in the Caltrans concept report on this subject. The FEIR needs 
to clarify this proposed pipeline route as it may relate to State Route 4. Is fee simple 
acquisition anticipated for this pipeline and could a trail to the Delta be constructed on CCWD 
right-of-way from the reservoir? Consideration of that potential should be included In the Rnal 
EIR. 

While the Reservoir Recreation Plan provides for access from the north and south, substantial 
recreational potential exists for residents with access from Alameda County - yet funding for 
improvements Is by CCWD residents. Will user fees be required to offset this Imbalance for 
access to the site from the south? To the extent possible, ease of access and availability of 
recreational facilities should be maximized for CCWD residents to the north. In addition, some 
separation is suggested for the multiple-use roadway described in the Recreation Plan, so that 
walkers/joggers will not be competing with the tram and/or other vehicles along the roadway. 

Figure 2-1 3 deals with the Old River Pipelines ff5 pipeline and electric transmission line. Will 
the transmission line be above or below ground? If above ground, the electro-magnetic force 
issues need to be discussed as they relate to the Discovery Bay area. The County urges new 
above-ground transmission lines to parallel existing lines wherever possible. The visual 
impacts of this facility need to be described. 

Pages 4-24 and 7-36 discuss impacts to levee habitat and site disturbance due to 
construction. Mitigation for these impacts should take place in a timely manner to offset the 
loss of habitat over time, as well as the lag time between habitat loss and full value of 
replacement habitat mentioned in the report. 

Impacts of the project to fish are found on page 4-54 of this report, generally indicating that 
mitigation would take place via contribution to fishery mitigation programs developed through 
the Two-Agency Fish Agreement. Does tNs Agreement depend on fish hatchery production 
as mitigation, rather than efforts to boost survival rates of naturally existing fish? As hatchery 
fish do not have the same survival rate as naturally occurring indigenous species, every effort 
should be made to protect existing fish. 

Mitigation for impacts to wetlands is discussed on page 7-37, describing mitigation of 
jurisdictional wetland areas at a rate generally exceeding 1:1. Contra Costa County General 
Plan policy supports mitigation of up to 3:1 in some cases to insure no loss of habitat values. 
In addition to mitigation specified in the report, the County encourages incorporation of 
wetlands creation end enhancement activities to the greatest degree possible as part of 
CCWD reservoir activities. 

Mitigation Measure 7-1 6 on Page 7-46 states that the County should limit subdivisions of 
adjacent parcels to prevent secondary impacts to Vasco Road relocation. The measure is 
loosely written and it is not clear what the DEIR preparers are recommending the County to 
undertake and the area where this measure is being encouraged to be applied. 



5-108 



mv- 12- 1992 15:42 FROM CCC COmUNITY DEUELOPNENT TO 97981452 P. 04 

Mr. Gary Darling Date: May 12, 1992 

EIR/EIS - Los Vaqueros -3- File: WA-3 



The discussion on requirements for offsetting the impacts to the San Joaquin Kit Fox are 
confusing as written and appear to be inconsistent with the requirements the County has 
recently experienced with the East Contra Costa County Airport; the County was required to 
provide a 3 to 1 acreage mitigation for impacted areas. The consistency of project mitigation 
standards by regulatory agencies for differing public and private proposals is confusing, ^^'^^ 
California Fish and Game and U.S, Fish and Wildlife requirements need to be reviewed for 
consistency with the proposed mitigation measures and the requirements on other nearby 
projects. The proposed mitigation measure 8-42 does not appear to be consistent with their 
stated rules. This decision could be precedent-setting. 

Is the Vasco Caves acquisition, discussed on Page 11-11, presumed to now be a project 1 
requirement? ^^"^^ 



The discussion on fire protection needs to be updated to reflect the merger of Byron Fire 
Protection District with the East Diablo Fire Protection District. 

On Page 20*6, Table 20-1 incorrectly indicates that Building Permits are issued by the 
Community Development Department; they are issued by the Building Inspection Department. 



14-12 



14-13 



The DEIR does not clearly identify the proposed haul roads for bringing rock and other 
construction materials and equipment to the project site; it should. Many of the roads in the 
area are rural In character, are already impacted by traffic, and structural integrity may be 
threatened by the weight associated with heavy construction equipment, A mitigation 14-14 
measure should be added which will require CCWD to work with the Contra Costa County 
Public Works Department in determining which haul roads will be utilized and the hours of the 
day when they can be utilized. 

The District watershed lands historically had more oak trees than presently exist. Extensive 

cattle grazing has limited the regeneration of new oak trees. The District should commit to 

an oak tree regeneration project to offset any impacts to the species as an ongoing function 

of watershed management. In addition, the species locatior^ and mitigation measures ^^'1^ 

associated with oak woodland replacement areas need to be more clearly outlined. Where will 

the oak woodland replacement areas be located? How will the impacts of woodland loss be 

mitigated, particularly until the trees reach maturity? 

Page 7-21 addresses project impacts to wetland areas and other significant natural 
communities. Contra Costa County is requesting CCWD consideration of participation in East 
County ecological and biological programs. This program generally would provide interpretive 14-16 
educational programs for students, and would be focused on wetlands and water issues. 
Some agencies ere currently involved in this program, which is being formulated, at least in 
part, for mitigation of impacts to wetlands from specific projects. 

As implementation of this project and fine-tuning of planning decisions go forward, the Water 1 
District should consider citizen advisory committee participation, such as those formed by the 14-17 
County for some of our larger projects. 



5-109 



MAY-12-1992 15=43 FROM CCC COtlMUNlTY DEUELORIEI-IT TO 979S1452 P. 05 

Mr. Gary Darling Date: May 12, 1992 

EIR/EIS - Los Vaqueros -4- File: WA-3 



The County urges the Water District to use local hiring end prevailing wage practices to the 
extent possible. 

Given the complexity of this project, the DEIR Is quite thorough and with some amendments 
should allow for informed decisions on the project approvals which are required. 



14-15 



R(3:\ 

(gJrOirllngXv 



Sincerely, 



Sunne Wright McPeak 
Chair 



5-110 



Responses to Comments of the Contra Costa County Board of Supervisors 



14-1. As described on page 1-15 of the Stage 2 EIR/EIS and Appendix B to CCWD's Section 404(b)(1) 
alternatives analysis, CCWD expended considerable effort and time to encourage participation by 
other agencies. CCWD has substantial information regarding the Kellogg Creek watershed that 
would allow impacts of a larger reservoir to be assessed should participation occur in the future. 
Because specific information is lacking regarding how large a joint-use reservoir might be, how 
such a reservoir might operate, what purpose the increased increment of storage might be used 
for, what the water source might be, and where the water might be used, CCWD and Reclamation 
believe that attempting to analyze impacts associated with a larger reservoir would be speculative 
and inappropriate at this time. 

1 4-2. The planning boundary for the City of Antioch was based on the sphere of influence that had been 
approved by the Local Agency Formation Commission as of September 1989. However, the 
current southern boundary should be shown along the three section lines to the north. The 
Oakley Water District boundary was based on that district's planning area boundary as of 
September 1989. 

Some annexations to the CCWD service area have occurred since the planning area used for 
determining the water demands described in the Stage 2 EIR/EIS was developed. These 
annexations are discussed on pages 18-1 7 of the EIR/EIS. These annexations result in only a very 
small increase in CCWD's buildout water demands. These additional demands are well within the 
accuracy limits of the original analysis. CCWD's contract with Reclamation for up to 195,000 af/yr 
is sufficient to provide service to the planning area described in the Stage 2 EIR/EIS, including the 
annexed areas discussed above. 

The possibility of extending water service to other areas in east county is a separate issue and is 
fully discussed in chapter 17 of the EIR/EIS. 

Although CCWD has entered into agreements with both East Contra Costa Irrigation District and 
the City of Brentwood, substantial new facilities would need to be constructed, and CCWD would 
need to expand its service area by annexing lands that are now outside of the CCWD service area 
to serve this area. Both these actions would require CEQA compliance. In addition, Los Vaqueros 
Project planning does not include providing sufficient facility capacity necessary to provide project- 
related water quality and reliability benefits to an expanded service area in eastern Contra Costa 
County. 

14-3. The Old River No. 5 and No. 6 pipelines would be located approximately 1,000 feet south of SR 
4. Although some latitude exists regarding the specific method used to acquire land, CCWD 
generally proposes to acquire pipeline alignments through fee acquisition. CCWD believes that 
a trail constructed along the various water conveyance pipeline routes is generally a compatible 
use. This potential use is described on page 12-31 of the Stage 2 EIR/EIS. 

1 4-4. CCWD will consider separating some of the multiple-use roadway as recreation planning proceeds. 
Such separation may involve moving portions of the roadway or may consist of designating new 
lanes. The issue of reservoir access from the south will be addressed during the development of 
a resource management plan to be prepared following certification of the Stage 2 EIR/EIS. 

1 4-5. The electric transmission line to the intake facilities will be above ground. CCWD and Reclamation 
believe that electromagnetic field effects are not an issue for this project. The strength of such 
fields diminishes rapidly near the edge of the right-of-way and is typically of concern only when 



Response to Comments of the Contra Costa County Board of Supervisors 

5-111 



residential density is higii near the electric transmission lines. The area through which the new 
line would pass is rural arxj no residences are located near the edge of the right-of-way. 

CCWD has planned its facilities to parallel existing facility alignments wherever practicable. 
Chapter 9, "Visual Resources", of the Stage 2 EIR/EIS descrit>es the visual impacts of the 
proposed electric transmission line and indicates that significant visual impacts would occur along 
the entire alignment. These impacts are identified as significant unavoidable impacts in the Stage 
2 EIR/EIS. 

14-6. Comment noted. CCWD and the various resource agencies with which CCWD and Reclamation 
have been working believe that the proposed mitigation for this impact on levee vegetation is 
adequate to offset any impacts. See also comments 2-25 and 2-26 by the U.S. Environmental 
Protection Agency. 

14-7. As a result of comments received on the draft EIR/EIS and meetings with the various resource 
agencies, CCWD and Reclannation have developed mitigation measures that not only reduce 
impacts to Delta resources, but actually improve conditions as compared to no project, particularly 
for winter-run chinook salmon and Delta smelt. These measures consist of revisions to the 
proposed project operations in terms of the timing and magnitude of diversions from the Delta. 
Under the proposed mitigation plan, CCWD will use a portion of the water stored in the Los 
Vaqueros Reservoir in lieu of direct diversions from the Delta, during the winter-run chinook 
salmon's season of highest vulnerability. This operation will allow CCWD to eliminate aN diversions 
from the Delta, including those from its existing intake at Rock Slough, for a total of approximately 
30 calendar days between March 15 and May 15 of each year. In addition, CCWD will generally 
not fill the Los Vaqueros Reservoir between March 15 and May 31. 

The revised project operations are fully described in the biological assessment for the proposed 
project as are the effects of the revised operations on special-status fish species. The mitigated 
operations are also described in Chapter 4 of the final Stage 2 EIR/EIS, along with a discussion 
of effects on other fish species. 

14-8. Comment noted. A detailed wetlands mitigation plan has been prepared and is included as an 
appendix to the final Stage 2 EIR/EIS. Generally, wetland mitigation areas to be treated exceed 
impact areas by more than 3:1. CCWD will consider incorporating wetlands creation and 
enhancement activities into the overall reservoir operations. 

1 4-9. Although the area through which the relocated Vasco Road would pass is zoned agricultural and 
is outside the urban limit line in Contra Costa County, CCWD and Reclamation recognize that 
relocating Vasco Road could result in increased pressure to subdivide lands along the entire 
roadway. Such sulxlivision could lead to secondary impacts on important natural resources. 
CCWD and Reclamation believe that Contra Costa County, as the local agency responsible for 
land use planning and regulation, should take steps to ensure that such sutxJivision does not 
occur in areas containing important resources. 

14-10. CCWD and Reclamation have continued discussions with the California Department of Fish and 
Game and USFWS and have developed additional approaches to addressing impacts on the San 
Joaquin kit fox that are generally consistent with the approaches used for other recent public and 
private projects in the area. These additional approaches are described in the biological 
assessment for the Los Vaqueros Project. The USFWS's biological opinion is summarized in 
Chapter 20, "Consultation and Coordination". 



Response to Comments of the Contra Costa County Boarri of Supervisors 

5-112 



14-11. CCWD has pursued acquisition of the Vasco Caves areas for some time and CCWD and EBRPD 
are committed to jointly purchasing the areas. CCWD and EBRPD will continue their efforts to 
acquire this area to preserve and protect its natural and cultural resources. Possession of the 
caves area by CCWD and EBRPD is expected by June 1994. 

14-12. Comment noted. These two fire protection districts have merged. The merger does not greatly 
affect the ability to provide fire protection sen/ices to the project area. 

14-13. Comment noted. The appropriate text has been modified in the final EIR/EIS. 

14-14. Section A-3 of the Stage 2 EIR/EIS Technical Report contains substantial information regarding 
the haul routes assumed in the Stage 2 EIR/EIS. CCWD and Reclamation recognize that the 
structural integrity of some of these roadways may be affected and will work with the county to 
identify haul routes. This potential impact is described as significant in Chapter 16, "Public 
Services", and mitigation measures are proposed to reduce these impacts to less-than-significant 
levels. 

14-15. CCWD believes that the mitigation plan it has developed for valley oak woodlands, which is 
included as an appendix to the final Stage 2 EIR/EIS, adequately addresses all these issues. 
Measures have been incorporated into the mitigation plan that include specific information 
regarding the locations and methods of planting, measures taken to improve the likelihood of 
regeneration, and the recovery of short-term wildlife values. 

14-16. CCWD would be very interested in providing such interpretive and educational programs and has 
included the concept of such programs in its recreational planning process. CCWD will therefore 
consider participating in the referenced programs. 

14-17. Comment noted. CCWD will consider developing a citizen advisory committee to encourage 
public participation in refining the recreation and watershed management plans. 

14-18. Comment noted. CCWD will incorporate local hiring and use of prevailing wage practices to the 
extent practicable. 



Response to Comments of ttw Contra Costa County Board of Supervisors 

5-113 



4 



BYPASS 

AUTHORITY 



LETTER NO. 15 

Joint Exercise of Powers Agency 

*jI^ City of Antioch City of Brentwood County of Contra Costa 



e'->N-3.-J/i r May 12, 1992 C^t^-. 35^ 

John Gregg ^--^\\3> j 

Program Manager 

Contra Costa Water District 

P.O. Box 4121 ' 

Concord, CA 94525 

RE: Draft Stage 2 EIR/EIS for Los Vaqueros , 

Dear Mr. Gregg: 

We have reviewed the Draft Stage 2 Environmental Impact Report for the Los Vaqueros 
Project and have the following comments. 

1 . The Delta Expressway Environmental Impact Report is tentatively scheduled to be 
released in July, 1992. The Delta Expressway preferred alignment is the northerly 
third of the East County Corridor Study in which the Contra Costa Water District 
participated. The Bypass Authority has met with commvmity groups, land owners, 
and East County Policy Makers, and based on their input, the preferred Delta 
Expressway Alignment was selected to be included in the Expressway EIR. The City 
of Brentwood and the City of Antioch have set land use policies which the EIR/EIS 
cites as criteria for alignment of the Los Vaqueros Pipeline. These same criteria 
were used in development of the East Coimty Corridor Study, as well as the Delta 
Expressway. Based on these criteria these two facilities should be parallel and 
contiguous where feasible to minimize environmental impacts. Therefore, the Los 
Vaqueros EIR/EIS should analyze the impacts of these facilities being parallel and 
provide mitigations where required. 

2. The discussion of Proposed Developments, on page 12-18, states that the Los 
Vaqueros pipeline would pass near several proposed development projects in Future 
Urban Area 2. There is also discussion of developments, both proposed and 
approved imder the planning process of the County, the City of Antioch, and the 
City of Brentwood General Plans, which may affect the planning for the aligrunent 
of the Los Vaqueros Pipeline. Since the Delta Expressway is a component of these 
general plans, it should be discussed on page 12-18 and shown in Figure 12-2. 



RECEIVED staff: 
Board of Directors: Ex OfTicio: Contra Costa County 

Tom Toriakson. Chairman dyofUvermore MAY 1 2 1992 255 Glacier Drf^e 

Barbara Guise Alameda County Martinez. CA 94553 

Joel Keller Contra Costa Water District (415)31 3-2382 

5-114 



John Gregg 
May 12, 1992 
Page 2 



3, The DEIR shoiold recognize that the Los Vaqueros Pipeline and the Delta Expressway 
rights of way may be contiguoiis and parallel, except at proposed interchange 
locations of the Expressway, such as at Laiirel Road, Lone Tree Way, Sand Creek 
Road, Balfour Road, Marsh Creek Road, and Walnut BoiJevard. At these 
interchange locations, the Delta Expressway right of way is planned to widen to 
provide for on and off ramps. The Los Vaqueros pipeline will cross these future 
ramp locations. At this date it appears that the pipeline construction may precede 
the construction of the roadway. Therefore, the Draft EIR/EIS, should provide ^c,, 
criteria for the design of the pipeline, in proposed interchange locations, that will 
minimize or avoid conflicts. If these ramp crossings cannot be avoided, then 
sufficient protection should be provided for the pipeline. The design criteria for the 
Delta Expressway requires the minimum radius of curvature to be 3000 feet. On 
the other hand, the design criteria for the Los Vaqueros Pipeline provides 500 foot 
minimum curve radii. Other design considerations include proper depth to avoid 
future relocations and avoidance of highway drainage facilities. 

4. One of the alignments identified for the Los Vaqueros Pipeline crosses the ridge 
through the Cowell Property south of Marsh Creek Road. In this same vicinity, the 
Delta Expressway will also have to cross this ridge but at a lower elevation to meet 
maximum grade standards. The DEIR/EIS sho\ild discuss the impacts of the pipeline , ^ . 
crossing the ridge in the same vicinity as the Delta Expressway crossing. Final 
design of the pipeline should minimize conflicts with grade and depth of the pipeline 
at this ridge location to prevent future relocation when the Delta Expressway is 
constructed. 

If you have any questions regarding these comments, please contact me at (510) 313-2255. 

Very truly yours. 



c/^ 



Lowell Tvmison 
Senior Qvil Engineer 
Major Projects 



C 



LT:TR: 
c:Darlmg.c5 



5-115 



Responses to Comments of the State Route 4 Bypass Authority 



15-1. Comment noted. The Los Vaqueros pipeline has been designed to generally be parallel and 
contiguous with the identified right-of-way for the Delta Expressway except where economically 
infeasitjie. The impact analyses contained in the Stage 2 EIR/EIS assumes that these facilities 
were parallel, and the identified mitigation measures were designed accordingly. 

15-2. Comment noted. The Delta Expressway has been incorporated Into most local plans. The 
referenced impact analysis was focused, however, on the effects of the Los Vaqueros pipeline on 
proposed and potential development. The Los Vaqueros pipeline will provide a buffer in some 
areas between the Delta Expressway and residential uses. 

15-3. CCWD has coordinated extensively with Contra Costa County regarding the alignment of the Los 
Vaqueros pipeline and its relationship to the Delta Expressway. At interchanges, the Los Vaqueros 
pipeline will either be outside the identified interchange areas or buried deep enough to allow the 
interchange facilities to be placed on top of the pipeline right-of-way. 

1 5-4. Where the alignments of the Los Vaqueros pipeline and the Delta Expressway are contiguous, the 
final design of the Los Vaqueros pipeline will account for the potential location of the Delta 
Expressway to avoid relocating the pipeline when the Delta Expressway is built. 



Response to Comments of the State Route 4 Bypass Auttniily 

5-116 



May 12, 1992 






Mr. Gary Darling 

Contra Costa County Water District 

Los Vaqueros Project 

P.O. Box 4121 

Concord, CA 94524- 

SUBJECT: Stage 2 EIR/EIS for the Los Vaqueros Project 

Dear Mr. Darling: 

The East Bay Regional Park District has reviewed the subject docunnent and offers 
the following comments. The EBRPD is identified as an agency which may 
administer the watershed recreation plan (p. 12-20). The EBRPD would have to 
use the subject document as a Responsible Agency and, therefore, it Is concerned 
that the document adequately address all the recreation related adverse impacts 
which could occur. The subject document addresses, at the conceptual level, an 
ambitious recreational development plan and its potential for regional-scale impacts 
(such as; traffic congestion, noise, air quality, and water quality). As the 
document refers to EBRPD as a potential operator under CEQA, it must provide the 
basis for the EBRPD to consider the concept of operating the recreational facilities 
associated with the Los Vaqueros Project. 

The EBRPD is concerned that the level of detail in the subject report is not 
sufficient to provide the basis for construction and operation of all the recreation 
facilities Identified. In general, the subject document leaves to future "specific" 
plans the details of vegetation management, wildlife management, cultural 
resource management, and recreational activity management. The assertion of the 
EIR/EIS Is that these specific plans can all meet their stated objectives without 
conflicting with each other. Based upon Its 56 years experience operating and 
maintaining recreation activity in similar large environmentally sensitive lands the 
EBRPD Is concerned that this assertion may not be correct. The EBRPD staff is of 
the opinion that there may be substantial changes to the conceptual recreation plan 
which would significantly alter the potential for adverse Impacts. These two 
factors may combine to make it desirable to prepare a subsequent EIR on a revised 
and more specific recreational use and resource management plan. 



16-1 



16-2 



RECEIVED 
MAY 1 2 1992 

2950 P«raltt Date Court. P.O. Box 5381 •0«lfKlCA»«)5 0381 •5l0.635.0l35'fftX5-.0 569.4319 LOS VAQUEROS 



Concerns about specific portions of the EiR/EIS are given below. 



-i^l^ i I M 6 9 S I S 8 I : A T 31-113 6-: 



Mr. Gary Darting 
May 12, 1992 
Page Two 

|<ellQ9a Creak Water Resources 

The discussion of reservoir water quality (p. 6-11) should be substantially 
expanded to include analysis of the Implications of algae blooms on recreational 
opportunities. While the text Indicates that blooms "may inhibit boating", It does 
not evaluate the probable frequency, duration, or severity of this effect. The text 
should be elaborated to include an analysis of probable dissolved oxygen levels, 
and the Implications of this upon potential recreational fisheries and upon the 
recreational value of portions of Kellogg Creek effected by released water from the 
reservoir. 

In addition to addressing questions about drinking water standards, the discussion 
also should specifically address the potential for the proposed recreational activities 
themselves to be adversely effected by water quality parameters. The discussion 
of fishery resources (pp. 6-15 to 6-16) should be augmented to explicitly consider 
the combined water quality effects of thermal Inversion, oxygen depletion, and 
reservoir drawdown upon the recreational fishery In the proposed reservoir. The 
mitigation discussion (p. 6-16) also should be substantially expanded. The existing 
mitigation measure should be expanded to specify the steps which would be taken 
if adverse water quality conditions were identified, if 'bluestone" (copper sulfate) 
treatment were to be used in the reservoir to control algae, the Impacts of the use 
of this chemical upon recreational fisheries should be evaluated. This discussion 
also should be expanded to include recreational fisheries enhancement measures 
which could be Included at the time of construction of the dam. Since material for 
the dam is to be borrowed from the reservoir bottom, the bottom contour of the 
reservoir could be engineered to provide spawning beds for warmwater lake 
species, thereby enhancing the fishery. 

Boating and fishing would be ma]or components of the recreation program, the 
success of which depends upon the measures taken to protect and enhance water 
quality in the reservoir. 

Vegetation Resources 

The discussion of mitigation for impacts upon vegetation (pp. 7-33 to 7-48) should 
be altered to Indicate that the creation of alkali wetlands, alkali meadows, claypan 
vernal pools and oak riparian woodlands are all experimental concepts. If attempts 
at "In kind" habitat replacement at a one-to-one ratio fall, "out-of-kind" wetland 
creation is likely to be required at two-to-one or greater levels. All recreational 26-6 

facilities and most recreational activities should not occur within the local sub- 
watersheds which drain Into these created habitats. The relatively level portions of 
the site are the most suitable both for recreation and for wetland creation. 
Therefore, the text should specifically address the feasibility of the planned 
recreation, given these potentially conflicting factors. 

5-118 



J 



t-e ■ d 



2. I t- I 6 9 S ©IS 



s I : A I 



3 01 



•:• 6 - o I - A U I'J 



Mf . Gary Darling 
May 12, 1992 
Page Three 



Wildlife Resourcas 

The discussion of impacts upon wildlife (pp. 8-13 to 8-38) should be augn^ented. 
During and immediately after reservoir construction, the more mobile wildlife 
species would be displaced to surrounding areas, including the EBRPD's Round 
Valley. This will result In increased mortality due to lack of resources (e.g., food) 
and hazardous conditions (e.g., raptorial birds being Icllled by windmills as 
documented In a recent study by the California Energy Commission for Alameda 
and Contra Costa counties). In the Round Valley area this nrH>rtality effect could be 
compounded by a similar displacement of animals from the approved Marsh 
Canyon Sanitary Landfill site and from the proposed Cowell Ranch Development. 

Cultural Resources 

The EBRPD is especially concerned about the potential for adverse impacts upon 
the Vasco Caves area. The combination of unique geologic, vegetation, wildlife, 
and cultural resource features of the Vasco Caves area were primary 
considerations in the EBRPD's designation of them as a potential regional parkland 
In its Master Plan. The discussion of mitigation for adverse impacts upon cultural 
resources (pp. 11-20 to 11-24) lacks the specificity needed to determine whether 
the proposed measures would be effective or feasible. Further, the EIR/EIS lacks a 
comprehensive discussion of the measures needed to protect all of the resource 
values present In the Vasco Caves area. As an example of the lack of specific 
mitigation measures, there is no mention of the need to arrest the normal bedrock 
weathering processes which threaten the prehistoric pictographs there. Similarly, 
there is no consideration of the elimination of windmills to reduce the presence of 
humans who might purposefully or Inadvertently damage the cultural resources. 
As an example of the lack of a comprehensive overview of the multiple resource 
values at the Vasco Caves, there is no description of the wind*erosion features 
(including tors, tafony, desert pavement, end concretions) which are among the 
geologic resources worthy of preservation at the Vasco Caves. Similarly, there is 
no discussion of the significance of or even the existence of a population of Palmer 
oak trees in the Vasco Caves area. These deficiencies may cast doubt upon the 
feasibility and effectiveness of measures Identified in the EiS/EIR to prevent 
damage because of the incorrect impression given that inaction constitutes 
preservation. 

Notwithstanding the comments above, the EBRPD is supportive of the wide range 
of mitigation measures which the CCWD has explicitly committed to carry out (pp. 
19-1 to 19-8). When such an early commitment Is present, It should be possible 
to carry out early preparations for these measures; for example, salvage 
archaeological investigations of affected cultural sites and the gathering of acorns 
for use In replacement plantings from the local oak trees which would be removed. 



16-7 



16-8 



16-9 



5-119 



SQ 'd 



l\ t- \ 6 9 9 I S 



3 fl 1 c 6 - 3 I - A y I 



Mr. Gary Darling 
May 12, 1992 
Page Four 



The EBRPD urges that this be done as it wlli take decades to reestablish oak trees. 
The EBRPD is especially supportive of the mitigation measures (p. 11-12) to 
protect the Vasco Caves from adverse Impacts associated with the realignment of 
Vasco Road and suggests that the protective fencing and posting be Implemented 
prior to road construction. The EBRPD will be pleased to cooperate v\/lth CCWD to 
mitigate and manage cultural and other resources which cross our common 
property lines at Round Valley and Morgan Territory. 

The EBRPD recognizes that a full and complete response to the comments above 
may produce significant new information leading to the necessity of revising and 
recirculating the draft EIR/EIS and thus causing a significant delay in CEQA 
processing. Alternatively, CCWD could continue the staged environmental review 
process already begun by preparing a subsequent (Stage 3) EiR based upon a 
specific vegetation, wildlife, cultural resources, and recreational facilities plan. The 
EBRPD would continue to offer its expertise in recreation and open space 
management to facilitate this. Based upon Its experience with water reservoir 
oriented recreational facilities, the EBRPD finds that the currently proposed 
conceptual recreation plan would not be feasible for this District to operate and 
would require substantial changes which will alter the potential for adverse 
impacts. Thus, responding to the comments above, and responding to what will 
undoubtedly be a different recreational facilities plan, would best be carried out in 
the context of a subsequent (Stage 3) EIR. The EBRPD strongly urges the CCWD 
to adopt such a procedure. 

Very truly yours, 



16-10 




T.H. LIndenmeyer 
Envlronnrtental Specialist 

cc: P. O'Brien 



5-120 



I 
I 
I 
I 

i 



Response to Comments of the East Bay Regional Park District 



16-1. Comment noted. CCWD believes that the Stage 2 EIR/EIS provides sufficient detail regarding the 
conceptual recreation plan to allow other agencies to use the Stage 2 EIR/EIS for CEQA 
documentation purposes if the conceptu£U plan is lmplen>ented as described. As CCWD develops 
final resource and recreation plans, any additional environnr>ental docun>entation necessary to 
comply with CEQA will be prepared. 

16-2. CCWD believes that the Stage 2 EIR/EIS fully and adequately describes the potential 
ens^ror>mental impacts that could result from implementing the conceptual recreation plan as 
described In the Stage 2 EIR/EIS. If detailed recreation planning indicates that the stated 
objectives cannot be met, or if substantial changes occur in the conceptual recreation plan, CCWD 
will prepare any additior^ environnnental documentation necessary to comply with CEQA. 

16-3. CCWD believes that the analysis contained in the Stage 2 EIR/EIS is adequate. Although algal 
blooms are possible, CCWD will maruge the reservoir to minimize such prot)lems because algal 
t)looms would adversely affect water quality. In addition, the proposed action would substantially 
increase recreation opportunities in the [xoject area. CCWD does not consider minor effects that 
only slightly affect such benefits to be environmental impacts that require detailed discussion. 

Fisheries do well in other reservoirs that store water diverted from the Delta, such as Contra Lonr^ 
Reservoir and San Luis Reservoir. No indication that conditions in the Los Vaqueros Reservoir 
would be substantially different exists. 

As descrit)ed in Chapter 6 of the Stage 2 EIR/EIS, the quality of water flowing in Kellogg Creek 
is very poor, except during brief high-flow events, because most of tfie Kellogg Creek flow is 
derived from poor-quality local groundwater. Regardless of condittons in the reservoir, the quality 
of Kellogg Creek flows would improve with implenrtentation of the project. 

16-4. As discussed above, other reservoirs that store water diverted from the Delta maintain substantial 
fish populations, and r>o indication that the Los Vaqueros Reservoir would be different than other 
similar reservoirs exists. CCWD recognizes that substantial opportunities exist to enhance fisheries 
hat>itat during reservoir construction and has included discussk>n of possible measures in its 
conceptual recreation plan. A detailed discussion of such measures is not included in the Stage 
2 EIR/EIS because the proposed reservoir would generally have beneficial effects on fish 
populatkxis and fishing opportunities. Therefore, no mitigation measures are required. 

16-5. Comment rK>ted. 

16-6. As noted in the Stage 2 EIR/EIS throughout the "Mitigation Measures* section of Chapter 7, 
*Vegetation Resources', creatir>g certain types of habitats would be experimental and uncertain. 
The mitigation programs developed in the Stage 2 EIR/EIS, which are included as appendk^s to 
the final EIR/EIS, recognize this uncertainty and therefore propose to mitigate impacts using 
proven methods. CCWD has conducted a miitiyear study of the effects of enhancing alkali 
wMlands and has documented success with these technk^ues. 

Most of the locatkxis at which CCWD is proposing to implement wetland mitigation would not 
have recreatkxial facilities nearby. A substantial amount of area exists within the Kellogg Creek 
watershed to conduct both recreatk>n and mitigation activities, and no conflicts are anticipated. 

16-7. CCWD and Redamatkxi recognize that some wfldlife species, especially larger, nx>t)ile species, 
wouki be displaced rather than directly eliminated by reservoir constaiction and flooding. 
Emigratkxi of displaced irxiivkjuals to surrounding lands woukj temporarily increase local 



A»«ponM to Comm»nt$ of ttm East Bay Regional Parti Diathct 

5-121 



populations and likely increase mortality rates as populations return to levels imposed by the 
can7ing capacity of these lands. Similar effects would occur as a result of other projects that 
displace wildlife species onto surrounding lands. 

An increased rate of mortality, in and of itself, would not constitute a significant impact, fvlortality 
rates fluctuate naturally whenever favorable environmental conditions result in growth of 
populations above the long-term carrying capacity of the fiabitat. A more important measure of 
impact is whether the carrying capacity, and hence the long-term population levels of Round Valley 
or other surrounding habitats, would b>e affected by construction of the Los Vaqueros Project. 

The net effect on wildlife populations in Round Valley and other nearby habitats would be to 
temporarily increase populations. Within several years or less, however, populations would return 
to preproject levels. Displacement of animals from the reservoir is therefore not expected to have 
any long-term detrimental effect on wildlife populations at Round Valley or other nearby lands. The 
long-term effects of habitat fragmentation caused by reservoir construction on the San Joaquin 
kit fox's use surrounding lands (including Round Valley) is discussed in the draft EIR/EIS and 
biological assessment. 

16-8. CCWD fias pursued acquisition of the Vasco Caves areas for some time and CCWDand EBRPD 
are committed to jointly purchasing the areas. CCWD and EBRPD will continue Jfs ^efforts to 
acquire this area to preserve and protect its natural and cultural resources. Possession of the 
caves area by CCWD and EBRPD is expected by June 1994. Since publication of the Stage 2 
EIR/EIS, CCWD and Reclamation have completed compliance with the National Historic 
Preservation Act and related requirements. The results of these efforts are descritjed in 
Attachment 3 to the final EIR/EIS. CCWD and Reclamation believe that the mitigation measures 
proposed in the Stage 2 EIR/EIS are adequate to reduce the impacts of the proposed action to 
less-tfian-significant levels. CCWD recognizes the importance of cultural resource sites in the 
project area and will make every reasonable effort to ensure that they are protected. The 
mitigation measures presented in the Stage 2 EIR/EIS, however, focus on eliminating and 
minimizing impacts of the project on cultural resources. The proposed action will not affect 
normal bedrock weathering processes; therefore, arresting these processes is not included as 
mitigation in the Stage 2 EIR/EIS. The proposed action will also not affect the number of people 
in the project area who maintain or are otherwise associated with wind energy production; 
therefore, no mitigation is required. 

The environmental setting contained in the Stage 2 EIR/EIS does not focus on features of the 
Vasco Caves area, such as unique geologic formations or vegetation resources, because the 
proposed action and alternatives would have no effect on these resources. However, the 
presence of these features has been documented in numerous reports published for the Los 
Vaqueros Project, including the Final Stage 1 EIR for the Los Vaqueros/Kellogg Project (Jones 
& Stokes Associates 1986) and the Results of Biological Resources Inventories and Habitat 
Evaluations in the Kellogg Creek Watershed (Jones & Stokes Associates 1989). 

16-9. Comment noted. CCWD intends to continue the cooperative relationship it has developed with 
the East Bay Regional Park District during formulation of the Los Vaqueros Project. 

16-10. See responses to comments 16-1 through 16-9. Implementation of the multi-agency Los Vaqueros 
Project PA will result in a finding of no adverse effect to sensitive cultural resources, according to 
the SHPO. A letter from SHPO documenting this finding is included in Attachment 3 to the final 
EIR/EIS. 



Response to Comments of the East Bay Regional Park District 

5-122 



OOARD OF TRUSTEES 

PRESIDENT 

Rorvok) Wheeler. Ph D 

AAortinez 

VICE PRESIDENT 
Dovid Jomeson. PhD 
Donville 

SECRETARY 
Fredo Ericksen 
Pleasant Hill 

ANTIOCH 
Charles T. Mozzei 

DR£NTWCK)D 
Vacant 

CLAYTON 
John Honley 

CONCORD 
Earl Mortenson 

CONTRA COSTA CO. 
Potricio Dello 
Jinn Pinckney 
Villiom Ross 

a CERRITO 

Df . Sedgwick Meod 

HERCULES 

Dr. Ninon Kafko 

LAFAYTTTE 
Morilyn Milby 

AAORAGA 

VoCQOt 

ORINOA 
Owfles Lupsho 

PINOLE 
Vocont 

pirrsouRG 

Robert Hussey 

RICHMOND 
Vocont 

SAN PADLO 
Vocont 

SAN RAMON 
Vocont 

WALNUT CREEK 
Noncy Ofownfield 



CONTRA COSTA 

MOSQUITO ABATEMENT DISTRICT 



1 55 MASON CIRCLE 

CONCORD. CA 94520 

[510] 685-9301 

[800)331-8321 

FAX: 685-0266 



LETTER NO. 17 

ADMINISTRATION 

MANAGER 
Charles Oeesley. Ph D 



\PR 2 1 1992 



April 20, 1992 



Mr. John S. Gregg 
Program Manager 
Los Vaqueros Project 
P.O. Box 4121 
Concord, CA 94 524 

SUBJECT: DRAFT STAGE 2 ENVIRONMENTAL IMPACT REPORT/ENVIRON- 
MENTAL IMPACT STATEMENT FOR THE LOS VAQUEROS PROJECT 



Dear Mr. Gregg: 

Contra Costa Mosquito Abatement District (CCMAD) staff have 
reviewed the Draft Stage 2 Environmental Impact Report/ 
Environmental Impact Statement for the Los Vaqueros project 
and we have some concerns that we feel should be addressed in 
the Final EIR for this project. 

Our first concern is the lack of any mention of potential 
public health concerns anywhere in the draft E.I.R. Although 
the project area is currently relatively unpopulated, the 
introduction of recreational facilities will bring in large 
numbers of people. Based on our past experience, the project 
area can expect problems with Culex and Culiseta mosquitoes. 
The Culex tarsalis mosquito is a potential vector of two viral 
diseases. Western Equine Encephalitis and St. Louis 
Encephalitis. 

The proposed mitigation to compensate for the loss of alkali 
marshes could lead to health problems, as well as a public 
nuisance. Pg. 7-38 (Monitoring) , mentions the necessity of 
monitoring mitigation to determine necessary corrective 
measures to remedy undesirable trends in the establishment of 
the wetlands. However, because many marshes are excellent 
grounds for extensive mosquito breeding, CCMAD needs to have 
access to the marsh and be able to monitor for potential 
mosquito production. 

Pools of standing water may be created by clogged screening ' 
devices in the new pumping system or the improper construction 
or expansion of water intake facilities (pg. 2-5) . These 
small pools of water can produce Culex pipiens and other 
mosquitoes in less then two weeks. 

Ultimately, recreational users will be subject to newly 
created mosquito sources or previously undetected sources. 

5-123 

MEMBER CALIFORNIA MOSQUITO Ann wrcTOR CONTROL ASSOCIATION 



17-1 



17-2 



17-3 



17-4 



These users will generate additional service request calls and will 
in turn significantly increase the level of service required from 
CCMAD. 

During the construction phase of the project numerous potholes, 
water pools and artificial containers can also be expected to 
provide excellent breeding grounds for immature mosquitoes. 

Comments to Draft Environmental Report: 

1) Chapter 3. DELTA SYSTEM HYDRODYNAMICS: Whenever new 
waterways are created or changed there is the possibility of 
water pooling in small pockets. These pools of standing water 
can produce mosquitoes in less then two weeks. 

2) Chapter 7. VEGETATION RESOURCES: New wetlands construction 
requires monitoring to ensure proper results. CCMAD should be 
included as a consultant prior to construction as well as 
after the wetlands are created. 



17-5 



17-6 



17-7 



3) Chapter 16. PUBLIC SERVICES: The study acknowledges some 
of the impacts on services that will be required because of 
the project. It is important to note here that CCMAD will 
also incur a significant increase in the level of service 
required under this project and this should be noted in the 
E.I.R. 



17-8 



4) HUMAN HEALTH: The Draft E.I.R. does not mention human 
health as a concern in the project area. The increase in 
human traffic can have a significant impact on public health 
because of potential exposure to mosquito borne diseases (as 
explained previously) . 

Recommendations ; 

1) It should be noted that this office has significant 
experience in the control of mosquito populations and should 
be consulted regarding the control of mosquitoes in the 
project area. 

2) When intake facilities are constructed or expanded the 
water should be as deep as possible with steep sides to 
minimize mosquito production. The water level should be kept 
as constant as possible to avoid production of floodwater 
Aedes mosquitoes. Whenever possible, emergent vegetation 
should be minimized, as this provides a protective and 
nutritive habitat for immature mosquitoes. 

3) During construction of the reservoir care should be taken 
to avoid leaving pools of standing water for longer than one 
week. 

4) CCMAD has extensive experience in designing wetlands to 
maximize their habitat value while minimizing mosquito 

5-124 



17-9 



17-10 



17-11 



17-12 



17-13 



i 



production. 



We strongly recominend that this office be 



consulted regarding the creation of any new wetlands in the 
project area. 

Therefore, we at Contra Costa Mosquito Abatement District feel that 
the above areas of wetlands/water, public service and public health 
should be addressed in the Environmental Impact Report. 

In closing, this office has the expertise, and should be consulted, 
regarding mosquito control in the project area. Please call our 
office should you have any comments or questions. 

Sincerely, 



17-14 



17-15 




Ray^ Waletzko 
Administrative Assistant 



CC: Los Vaqueros File 



5-125 



Response to Comments of the Contra Costa Mosquito Abatement District 



17-1. As with other reservoirs in the area, portions of the Los Vaqueros Reservoir may present 
oppxjrtunities for mosquito production. However, because of prevailing winds In the project area, 
the reservoir will exhibit substantial wave action much of the time and most of the reservoir surface 
will not provide conditions suitable for mosquito production. In addition, the reservoir will support 
populations of mosquito-eating fish and amphibians. 

CCWD conducted a brief survey of other agencies operating similar reservoirs in the area and 
received no repxirts of excessive mosquito production. CCWD will work closely with the mosquito 
abatement district to ensure that public health problems do not occur. 

17-2. CCWD believes that wetland mitigation sites in the project area would not expose recreation users 
at the Los Vaqueros Reservoir to an excessive mosquito nuisance. CCWD would provide the 
mosquito abatement district full access to all wetland mitigation sites. 

17-3. The fish screen and pumping facilities of the new Delta intake would be connected to Old River 
by a short concrete intake channel. When the pumps are not operating, water in the intake 
channel would circulate with the currents in Old River. 

Grading the intake and transfer facility sites would be done according to Contra Costa County- 
approved grading plans and would be designed to avoid water pooling. Runoff would be 
channeled to a drainage ditch similar to ditches in use on Byron Tract for agricultural drainage. 
CCWD does not expect the site to notably increase mosquito levels above background levels. 

17-4. Certain small portions of the reservoir and small water bodies, such as stock ponds and minor 
drainages, could expose recreation users to mosquitos. CCWD would either implement measures 
to deal with complaints or request services from the mosquito abatement district. Should district 
services be necessary, CCWD would provide appropriate funding. 

1 7-5. Some additional pooling of water could occur during the construction phase of the project. Any 
pooling that would occur would be tempxjrary, however, and would be corrected once proper 
drainage of construction sites has been established. In addition, most of this ponding would occur 
in the winter when mosquitos are less prevalent. Also, few people would be exposed to these 
potential sources of mosquitoes. If unexpected problems result, CCWD would request assistance 
of the mosquito abatement district. 

17-6. See response to comment 1 7-3. 

17-7. See response to comment 17-2. 

1 7-8. If mosquito problems arise on CCWD watershed lands and if CCWD does not Itself implement 
remedial action, the mosquito abatement district could experience some increase in service calls 
because of the Los Vaqueros Project. See response to comment 1 7-4. 

1 7-9. See response to comments 1 7-4, 1 7-5, and 1 7-8. 

17-10. Comment noted. CCWD recognizes the mosquito abatement district's experience in mosquito 
control and will consult with the district whenever appropriate. 

17-11. Water level at the intake site would be controlled both by tidal action and the volume of water 
flowing to the intake from upstream. Once the intake is constructed, affected levees will be 



Response to Comments of the Contra Costa MosquHo Abatement District 

5-126 



recontoured similar to existing levees. Because the intake channel would be constructed of 
concrete, potential emergent vegetation at the intake site would be minimized. 

17-12. Several sedimentation ponds will be required during construction to prevent silt-laden runoff from 
entering Kellogg Creek. Beyond this type of environmental mitigation requirement, CCWD will 
instruct its contractors to minimize the potential for ponding during project construction. 

17-13. CCWD recognizes the district's expertise. CCWD's environmental consultants have met with the 
district and CCWD will continue to consult with the mosquito atatement district as CCWD 
develops its wetland mitigation plans. 

17-14. See responses to comments 17-1 through 17-13. 
17-15. See response to comment 17-13. 



Response to Comments of ttie Contra Costa Mosquito Abatement District 

5-127 



LETTER NO. 18 

'" ""■" SOUTH DELTA UlflTfR flGfflCy 

904 BANK OF STOCKTON BiM-DtHG 

31 I EAST MAIN STREET 
STOCKTON. CAUFORNIA 0S2O2 

TEl^PHONE 120S1 e<J 5551 Gjurod 

Ibtamon Witaon. Hoslelt & WhHndge 

f LiiQH'iaer: 

AKorez GeraU T. Otob 

March 26, 1992 



Alv Hildetirand 



K. Ferguson 

BuuJietli 



Mr. John S. Gregg 

Program Manager, Los Vaqueros Project 

Contra Costa Water District 

P.O. Box 4121 

Concord, CA 94524 

RE: 2/92 Draft Stage 2 EIR/EIS 

Los Vaqueros Project SCH#91063072 

Dear Mr. Gregg: 

On behalf of the South Delta Water Agency (SDWA) , 
I am submitting the following preliminary comments on the 
February 1992 Draft EIR/EIS for the Los Vaqueros project. 

The Draft EIR/EIS should be expanded to provide model 
run results and a discussion of the potential effects of 
the Delta diversions at the maximum rate applied for (600 
cfs) and at lower rates on the water level and drawdown 
problems in the southern Delta, particularly in Old River 
and Middle River. 

The State and Federal Delta exports have caused 
considerable problems in lowering water levels and often 
dewatering channels in the South Delta in the vicinity 
of the exports. Following litigation and negotiations, 
the SDWA has now arrived at a draft agreement with these 
entities to mitigate those effects. The Draft EIR/EIS 
should analyze and discuss whether these proposed additional 
Delta diversions would increase or aggravate those problems 
assuming the present case, namely that the southern Delta 
barriers under discussion as part of the negotiated settlement 
are not in place. 



18-1 



18-: 



I 
I 

1 
I 



I would also like to request a copy of the Technical | 
referred to in the Draft EIR/EIS at nape S-l"^ and * 



Report referred to in the Draft EIR/EIS at page 5-13 and 



I 



RECEIVED I 

5-128 MAR 3 1992 

I 



March 26, 1992 
Page -2- 



elsewhere. The Agency may wish to submit further comments 
after reviewing the Technical Repott. 

Yours very truly, 

WILSpN, HOSI^ETT & WHITRIDGE 




DAVID WHITRIDGE j 
DW/rdb \ 



5-129 



Response to Comments of the South Detta Water Agency 



18-1. As part of the water rights process, CCWD plans to amend its petition to conform to the analysis 
performed for the EIR/EIS (intake capacity of 250 cfs). Increasing the intake capacity to 600 cfs 
would require subsequent CEQA (and perhaps NEPA) compliance review. The Stage 2 EIR/EIS 
discusses the changes in water surface elevation attributable to project operation on page 3-14 
and discusses other hydrologic and water quality effects of changes in flow regime on pages 3-25 
through 3-34 and pages 5-17 through 5-34, respectively. 

18-2. The existing conditions analysis completed for the Delta system hydrodynamics, Delta system 
fisheries resources, and Delta system water quality chapters of the Stage 2 EIR/EIS assume 
facilities, water supply demand, and operational rules that existed in 1990 were in effect and, 
therefore, did not include any barriers in the southern Delta. 

Effects of the proposed project on water level changes are discussed on page 3-14 of the Stage 
2 EIR/EIS and are clarified in a subsequent letter from CCWD to the South Delta Water Agency. 



Response to Comments of the Soutti Detta Water Agency 

5-130 







Contra Costa County 

FLOOD CONTROL 

& Water Conservation District 

April 13, 1992 



LETTER NO. 19 

J. Michael WaHord 

ex officio Chiel Engineer 



Milton F. Kubicek, Deputy Chiet 

255 Glacier Drive, Martinez, CA 94553-4897 

Telephone (510)313-2000 

FAX (510)313-2333 



John S. Gregg 
Program Manager 
Los Vaqueros Project 
P.O. Box 4121 
Concord, CA 94524 

Dear Mr. Gregg: 



File: 97-109 



We have reviewed the Draft Stage 2 Environmental Impact Report/Environmental Impact 
Statement for the Los Vaqueros Project (Stage 2 EIR/EIS) which was received by our office 
on March 11, 1992, and submit the following comments. 

The proposed pipeline and pipeline alternatives pass through several formed and unformed 
drainage areas. These areas have existing drainage facilities, creeks, drainage ditches and 
proposed drainage facilities. 

The EIR should include the following information regarding the NPDES Permit: 

"Applicant shall comply with aU rules, regulations and procedures of the National 
Pollutant Discharge Elimination System (NPDES) permit for municipal, construction 
and industrial activities as promulgated by the California State Water Resources 
Control Board or any of its Regional Water Quality Control Boards (San Francisco 
Bay - Region II or Central Valley - Region V)." 

In genc-al, the pipeline design for the selected alternative, when developed, must address 
all conflicts with existing local drainage and future drainage improvements. The plans must 
clearly identify existing facilities and drainage patterns. In areas zoned for development, the 
pipelines must provide for anticipated future drainage lines. The EIR will need to address 
mitigation measures in regards to existing and proposed drainage facilities, creeks and 
drainage ditches. 

The pipehne alternatives shown pass through several proposed drainage areas within which 
the size and location of drainage facilities are known. The Contra Costa County Flood 
Control and Water Conservation District (FCD) will provide horizontal and vertical locations 
of these facilities when needed. There are other areas for which the FCD has no proposed 
drainage facilities but where existing creeks and drainage swales suggest where future 
drainage channels and pipelines may be placed. At creek crossings (see enclosure for major 
crossings) Los Vaqueros pipelines need to be depressed to reflect possible channel 
improvements. At drainage swales, a minim um cover of 15 feet (top of pipe to existing 
ground) will be required to allow for installation of future gravity drains. RECtl^^u 

5-131 APR 2 mi 



19-1 



19-2 



John S. Gregg 

Los Vaqueros Project 

97-109 

Page Two 



Creek crossings will also require flow diversion plans. Rockslope protection, underlain with 
filter fabric, must top the trench and will need to extend upstream and downstream from the 
crossing at least 10 feet beyond the outside diameter of the pipe. Three foot cutoff walls 
will also be required at the upstream and downstream end of the rock slope protection and 
will need to extend up the banks to the design high-water line. 

We appreciate the opportunity to review this Stage 2 EIR/EIS and welcome continued 
coordination. If you have any questions, please call Joan Rushton at 313-2286. 



Veiy truly yours, 





Phillip Harrington 
Senior Civil Engineer 
Flood Control Engineering 



PH:JR:kd 
c:Gre97109.t4 

Enclosure 

cc: J. Rushton, Flood Control 



5-132 



Response to Comments of the Contra Costa County Flood Control and Water Conservation District 

19-1. CCWD would comply with all the applicable referenced rules, regulations, and procedures, and 
is designing the conveyance pipelines to adhere to all conditions placed on new development 
within the 100-year floodplain. 

CCWD has extensively worked with and will continue to work with local agencies and developers 
to appropriately locate the project's water conveyance pipelines. Mitigation measures are 
recommended in the Stage 2 EIR/EIS to protect future and existing land uses and sensitive 
vegetation and wildlife resources. 

1 9-2. CCWD has contacted the Contra Costa County Flood Control and Water Conservation District and 
has requested and received various design criteria. CCWD intends to continue to coordinate with 
the district as it designs the project's conveyance facilities. 



Response to Comments of ttie Contra Costa County Flood Control and Water Conservation District 

5-133 



Sheriff-Coroner^ ,^^^, 

Field Operations ^Kj i"^ ^l.^. 

Administrative and Community Services 
Irtvestigation Division 
Patrol Division 

1960 Muir Road 

Martinez, California 94553-0039 

(510)313-^^'=''* 

March 24. 1992 



Contra 

Costa 

County 



LETTER NO. 20 

Richard K. Rainey 

SHERIFF-CORONER 

Warren E. Rup( 
Assistant Sherifl 

Gerald T. Mitosinka 
Assistant Sheriff 

Rodger L. Davis 

Assistant Sheriff 



Mr. John S. Gregg 
Program Manager 
Los Vaqueros Project 
P.O. 60x4121 
Concord. CA 94524 

RE: Los Vaqueros Project Draft Stage 2 EIR/EIS 

Dear Mr Gregg 

The following comments are in reference to the subject of law enforcement 
services as noted in this draft (pages 16-5. 16-15, 16-22) see attached. 

The Contra Costa County Sheriffs Department is highly recognized for its 
ability to provide customized law enforcement services. Though we would be 
happy to provide the indicated level of service established In this draft, we 
would not want to be limited by these early projections. 

Our contract law enforcement projects serve as models throughout the state, 
and Los Vaqueros would be no exception. We look forward to matching our 
services with your project's needs. As those needs become more evident with 
time, we hope your staff feel free to contact our agency for any desired 
assistance. 

Sincerely, 

Richard K. Rainey. Sheriff-Coroner 
Contra Costa County Sheriffs Department 



20-1 



Lt. Scott L. Parsons. Commander 
Administrative and Community Services 

RKR:SLP 



RfCEIVEO 

MAR 2 7 iqq? 



5-134 



AN EQUAL OPPORTUNITY EMPLOYER 



Response to Comments of the Contra Costa County Sheriff-Coroner 



20-1. Comment noted. CCWD recognizes that the projections contained in the Stage 2 EIR/EIS are 
preliminary and will work with appropriate law enforcement agencies to determine appropriate 
force size and the best methods for providing such service. 



Response to Comments of ttie Contra Costa County Sheiiff-Comner 

5-135 






Dear Mr Gregg 



LETTER NO. 21 



14 May 1992 
Sunol, Ca. f\>-vyi'4 



I atTen<Je<J the Apnl ?th hearing on the Los Vaqueros Stage 2 EIR /I IS Due to difficulties 
in locating &rana<Ja High School, I arrived rventy minutes late. To my surprise, the 
hearing vas already closed Therefore, I am sending my remarks by mail I realize that 
these remarks vill arrive after your deadline of May 12th, but hope that since I 
attended the hearing, they vill still be included in the Final Stage 2 EIR /IIS 

I am vriting these comments as a private citizen, but as I am also a park natioralist, I 
feel <rualified to correctly identify vildlife species. I testified at the hearings on the 
Vasco Road relocation EIR to bring your attention to a breeding pond for California 
Tiger Salamanders, iliich vas overlooked in that EIR. The pond is located on the Miguel 
property approximately 800 feet south of the intersection of Camino Diablo and Cmyxo-^ 
Vaqtjeros roads. I lived at Rt. 2, Box HJK, across Camino Vaqueros from the pond. I sav 
California Tiger Salamanders around my home and in the pond almost every vinter 
Having shared this information at the Vasco Road Relocation hearings, I vas very 
disappointed that this location vas not indicated in the Stage 2 EIR ZEIS maps I am 
enclosing a copy of map 8-1, vith the location marked. I have also marked the location 
of Tncolored Etlackbirds I observed on my property. I sincerely hope this information 
vill be added to all relevant portions of the Final Stage 2 Los Vaqueros EIR ZEIS. 

As a taxpayer vhose property bounds the proposed proiect, I vas (and still am) appalled 
that California vater lav does not allov those vho vill be directly affected by a project 
to vote on it. I personally vill mourn the loss of beautiful Vasco Valley, vith its 
endangered Valley Oaks, San Joaqtiin Eit Foxes, Red-legged Frogs and other vildlife. 
shoiild the reservoir be built. I favor the Middle River Intake /EBMUD Emergency 
Supply Alternative, vhich votild accomplish yotir goals of improving quality and 
reliability of vater supplied to CCVD customers vithout building a reservoir and 
therefore minimize detrimental effects to the environment. 

Sincerely, 

Joanne Dean-Freemire 






21-1 



21-2 



cc: Contra Costa County Supervisor Tom Torlakson 
California Assemblyman Phil Isenberg 
California State Senator Daniel Boatvright 
XSS. Congressman George Miller 



MAY 1 8 W^ 



5-136 




Figure 8-1. 

^ Occurrence of Special-Status Wildlife 
\ rd^pedes in the Vtdnjty of the 
Kellogg Creek Watershed 



Legend 

A San Joaquin kit fox 

^ Burrowing owt 

A TMcoIored blackbird 

# Alameda wtilpsnake 

O Canfomla red^egged frog 

■ CaWomla tiger salamander 

O Western pond turtle 

(^ Curve-footed fiygrotus diving beetle 

^ Fairy sfirfmp 




Mill 



Response to Comments of Joanne Dean-Freemire 



21-1. As stated in the final Vasco Road and Utility Relocation Project EIR in response to a similar 
comment from this commenter, CCWD fully recognizes the existence of the tiger salamander 
population this commenter describes and appreciates the efforts undertaken to make CCWD 
aware of this consideration. When wildlife resources were mapped in tx)th the draft Vasco Road 
and Utility Relocation Project EIR and the draft Stage 2 EIR/EIS, Information was limited to those 
resources that could be affected by the proposed project and alternatives. This specific 
population, along with other wildlife populations that would not be affected, was therefore not 
discussed in these environmental documents. The population has been added to Figure 8-1 . 

21-2. Comment noted. CCWD believes that the Los Vaqueros Project, although resulting in some 
impacts, will preserve a large contiguous area that contains unique environmental and cultural 
resources that could otherwise be subject to future development. Although the Middle River 
Intake/EBMUD Emergency Supply Alternative would meet CCWD's water quality goals, it could 
not meet CCWD's reliability goals. 



Response to Comments of Joanne Dean-Freemire 

5-138 



GREENBEUX QLLIflNCE 



TEL:l-415-543-109; 



May 13,9; 



14 :03 No .007 F .01 






BouutD OP DnuicTORS 
Bud Jofaiu* 

PrttidtHl 
Andivw ButItT* 
ZachCowftn* 
Tri»h Mulvey* 
Audrtv Penn Rodffers* 

Vict Frttidenti 
\trry Ton*"* 

StcrtlarfTrtasvrfT 
BobBennan* 
[>»vW Bomberger 
Robctta Borgonovo* 
RkturdCiuUno 
DoflDicken*OM 
VoUu.T Eu«l«* 
Oorge Ellman* 
JohnEnklna 
John Flof otto 
john-Soott For«ter 
ijtuifT W C«e 
DonCilnK>rv 
Robert V.hUwn 
Rnliml R. Jol>n»<.'H'> 
T.J. Kent, Jr. 
BobM«ng» 
14a«v«KtitcheU 
M«n^B.MItiHj<» 
Andrew Na»h 
LennieRob«rts 
NifM* Stewnri 
Qkai Str<iu» 
Dm Sw»nhuy«oi* 
Litney Ihonuoii 
Btubira WinUfvki 
RBOAt* Woodbury 
Gwy ZimnxerniAn* 
'Extettttvt CommitUef 

ExBCurivfi DiKisLTw 
L«nyOrm«n 

AUVMUKY COMMITTTJ. 
How«r(1 Allwi 
Robert AuxsbuTRCT 
L«li< 5. Ayers 
Tucy W*kc 
lOM^h Dodovitz 
Lewj* H. ButlM 
Pknida CVmipion 
low Oow«r-Hoglc 
Mn. K«iph K. DavlM 
Lauimce Dawson 
ReiwdiRoM 
Kit Dove 
B»rb«i« BAttoum 
Wmi*in D. Evers 
Moit FlelthhAcker 
juneFootc 
Eikvn K Growald 
AUrcd litller 
1. MlchaeJ Hcynun 

Joteph C. Hou^teUng 
An»n U<x>bs 
Hucy Johiuion 
Robert Kir kwood 
Melvin !> l*ne 
Putnam Livermore 
L*wr«r)c« Livingston, Jr. 
P«imeU Upyd 
Irtvin Uickrnan 
Sylvb McLaughlin 
TneodOK Osinund»an 
N««l R. Pelrc« 
Canrge A S«>f» 
Mn. WUlUm Slri 
W»ll»c*Si*gner 
Mntjoiic S<CTn 







LETTER NO. 22 



P FOP IE FOR Ope n Space 



Cc^- 






^f J 



John Greg2 

ProgTAm Mtnager Los Vaqueros Project 

P.O. Box 4121 

Concord, CA 94524 

Rt: Conuneots uf Los Vaqueros Project Draft Stage 2 EIR/EIS 

Dear Mryuregg: 

Oreenbelt Alliance has the following queationt on the Los Vaqueros 
EIR/EIS. 

What is the size of the right-of-way Ak the Los Vaqueros pipdine? 

The Delu Expressway/East County Corridor/Mid State Toll Road have 
each identified a road alignment that is the same as the Los Vaqueros 
pipeline. Will Contra Costa County, State Route 4 Bypass Authority, or the 
California Toll Road Company each be required to purchase right-of-way 
along the Los Vaqueros pip^ine from the Contra Cosu Water District at full 
market value? 

What deed restrictions could Contra Coata Water District place on the 
Lot Vaqueros pipeline right-of-way to prevent its incorporation into the 
Delu Expressway/East County Corridor/Mid State Toll Road and thereby 
mitigate the adverse impacts of that project? 

Brentwood, Cowell Foundation new town, Oakley, projects on Hotchkiss 
TraclL^ and Mountain House are each planning nu\}or lewer treatment and 
discharge into the delu. 

What level of treatment for fresh water intake will the Contra CosU 
Water District be required to perform to maintain water quality, meet water 
Quality goals, and reduce salu for water stored in Los Vaqueros? Is this level 
of treatment a part of the Los Vaqueros project? What will be the capital 
cost, financing cost, and operattonal ooau of tbla treatment facility? 



Vv.vv^ 



22-1 



22-2 



22-3 



22-4 



Could Los Vaqueros accommodate 100,000 
storage from East Bay MUD? 



5-139 



150,000 cubic yards of water 



[more] 



22-5 



22-6 



MAIN OFFICE ♦ 116 New Montgomery Sult«640, S*n Pranr inco CA 94105 ♦ (415)543-4291 
SOUTH BAY OHFlcn ♦ 1922 The AUmedi Sullf213, SwiJofciCA 95126 • (40t5) 9tO-0539 

The Bay Area - Keep It Green 



RECEIVED 
MAY 1 3 1992 



6REENBELT PLLIANCE 



TEL: 1-415 



1093 



Maij 13.92 14 :04 No .007 P. 01 



Los \^qu6ros 



Page Two 



What amount of water utorage could Lot Vaqueroi accommodate from the East Contra 
Costa Irrigation District and the Byron Bethany Irrlgatioa District? 

What level of water treatment from tfte irrigailon districts would be required to mainuin 
water quality in Los V^queros In light of lewage discharge from communities in East Contra 
Costa and San Joaquin County? 

Wb«re is the intake for Lofi Vaqueros and tbt Byron Bethany and East Contra Costa 
Irrigation Districts in relationship to existing and proposed sewage treatment and discharge for 
Brentwood, Cowdl Foundation new town, Oakley, Mountain House, Byron airport, and all 
projects on Hotchkiss IVact? 

What actions will be necessary by Contra Costa Water District to protoa watar quality for 
to ratepayers? 



22-7 



22-8 



22-9 



Sincerely, y yM 

MarkEvanoff // ■ 

Field Repreaeotadve / / 



5-140 



I 



Response to Comments of the GreenbeK Alliance 



22-1. The right-of-way for the Los Vaqueros f>ipelir>e would be 125 feet wide to accommodate both 
permanent and construction activities. Some areas near OW River may require a greater right-of- 
way width because of unstable soil conditions. 

22-2. The Los Vaqueros Pipeline has been located by CCWD to follow existing utilities, where 
practicable. The Intent of this objective was to minimize Impacts on land owners and land uses. 

During this location process, CCWD has held numerous meetings with property owners and 
continues negotiating with them on Issues related to compatible adjacent and surface uses of the 
pipeline right ^Df -way. 

It Is CCWD's understanding that a joint use Delta Expressway and Los Vaqueros Pipeline right-of- 
way Is not acceptable to Contra Costa County or the state. 

22-3. See response to comment 22-2. 

22-4. Comment noted. CCWD wPI review plans and coordinate with project proponents on future 
wastewater discharges into Old River to minimize effects on CCWD's water supply. 

22-5. CCWD is not proposing to meet Its mineral water quality goals through water treatment. The Los 
Vaqueros Reservoir would allow CCWD to store high-quality Delta flows for use when Delta water 
quality deteriorates. Therefore, additional treatment costs are not expected. To maintain water 
quality in the Los Vaqueros Reservoir, CCWD wHI monitor th»e quality of water at the intake site and 
divert water to the resen/oir only during periods of acceptable water quality (see page 2-6 of the 
Stage 2 EIR/EIS). 

22-6. During planning for the Los Vaqueros Project, CCWD solicited the participation of other agencies 
and entities that could have benefitted from the project. Advantages of such an approach include 
more effective regional water planning and lower project costs to CCWD ratepayers and potential 
participants. Although Alameda County Water Conservation District Zone 7 and the East Bay 
Municipal Utility District showed some interest initially, each subsequently declined to participate 
in the project. CCWD's efforts to develop participation are summarized on page 1-15 of the Stage 
2 EIR/EIS and are fully documented in CCWD's Section 404(b)(1 ) Alternatives Analysis for Meeting 
Water Quality and Reliability Objectives (1991). 

Because no other agency chose to participate, CCWD configured the Los Vaqueros Project to 
serve only CCWD's needs. The project corwists of a 100,000-af capacity Los Vaqueros Reservoir 
that releases water directly to the Contra Costa Canal. The reservoir would not be capable of 
storing water In addition to the 100,000 af required to serve only CCWD purposes. 

Considerable engineering and environmental work has been completed since the decision was 
made to pursue a CCWD-only Los Vaqueros Project. This work has been based on a CCWD-only 
project 

22-7. See response to comnr>ent 22-6. 

22-8. In addition to the measures described In response to comnrient 22-5. the sizing of the reservoir, 
dlverskm schedule and criteria, and all other project operations have been developed to account 
for all water quality parameters of concern in Old River. The referenced discharges have been 
considered In developing project operations, and no additional water treatment would be required. 



R9spons» to Comirmnts of the Graenbelt Mianc* 

5-141 



22-9. CCWD is aware of these potential future wastewater discharges arxJ is coordinating with various 
project proponents and regulatory agencies to ensure tliat the quality of CCWD's water supply 
would not be negatively affected by these discharges. Many of these discharges would involve 
land disposal nnethods. 



Response (o Comments of the Greent)elt Alliance 

5-142 



I 
I 






LETTER NO. 23 



May 5, 1992 

James A. Hanson 
5340 Degnan Dr. 
Martinez, CA 94553 



RECEIVED 

MAY 1 1 1992 

Public Information Office 
Contra Costa WpterDistnct 



Contra Coata Water District 
1331 Concord Ave. Box H20 
Concord, CA 94524 



RE: Los Vaqueros EIR Comments 



These are written comments in response to the recently 
released EIR since I have not been able to attend the 
presentations . 

As a voter, this proiect was submitted on the basis of 
reducina salinity and improvin9 the existing water supply to 
existing customers. The Los Vaqueros EIR focuses on the 
environmental impacts to the wildlife and cultural history of 
tnat Darticular site. 



The proiect has not been presented as a water source for 
planned housing ana commercial developments, particulariy in the 
East County. If that is in fact ojie of the goals of this project 
2, as a district customer, wish to know that and what the impacts 
will be. If rattt-payers aie paying to supp'ly wcat.er fc^i iiew grc'Wth 
they should told tnat. Sp^eci f i ca 1 1 y : 

1. The EIR and District public information should i-iiiectiy 
and prominently state this a& 



.S dS. a P'lCije-Cl Q'jcjj. 

2. If any Los Vaqueros water 



;>ew 



_ isto bfuaecfcn' large 

development because existing supply is inadequ*?-tf , tlit- EIR snoula 
include a discussion of the traffic, public services, and ail 
other environmental impacts that increased water supply woula 
n^ake possible. 



23-1 



Thank you for y. 
recuests if warranted. 



attention to these comments, and my 



::■ - ncerei V , 



8^ ;S r: e s h . H ■; n ;=. o n 



5-143 



Response to Comments of James Hanson 



23-1. The planning assumptions with which the project was formulated are described on pages 1-6 
through 1-10 of the Stage 2 EIR/EIS and are discussed in greater detail in CCWD's alternatives 
analysis required by Sectbn 404(b)(1) of the Clean Water Act. 

To meet the water needs of planned future growth within its service area, CCWD will need to divert 
Its full contractual entitlement of CVP water from Reclamation. See also response to 
comment 14-2. The Los Vaqueros Project does not materially affect CCWD's ability to provide 
water to its sendee area. The Los Vaqueros Project would eliminate the need to make some 
improvements to the Contra Costa Canal system but would not significantly alter the amount of 
water thiat can be delivered to the CCWD service area because other physical limitations in the 
delivery system would still exist. The Los Vaqueros Project would be designed to divert to the Los 
Vaqueros Reservoir a portion of CCWD's contracted water supply when Delta flows are high and 
water quality is good. When water quality in the Delta is poor, CCWD would release water from 
the reservoir and reduce pumping from the Delta. 

The Los Vaqueros Project would not materially increase the water supplies available to CCWD, but 
would improve the overall quality of CCWD water supplies. 



Response to Comments of James Hanson 

5-144 



^ 



Mil, fr m. .> ■ ■ ^ 



• 
\ 

I 



s : e 3 



J) K r. 1 A 

May 12, 1992 



w 



LETTER NO. 24 

A \ 1) 




dc-. 


VW VSr^^ 


bl-^.,... 





Mr. John Gregg 

Contra Costa Water District 

P. o. Box H20 

Concord, CA 94524 

Dear Mr. Gregg: 

Re: Comments on Draft EIR/EIS for the Los Vaqueros Project 

We are taking this opportunity to submit the following comments 
regarding the DEIR/DEIS for the Los Vaqueros project. 

1. Waterfowl Hunting 

The project as proposed does not include waterfowl hunting at 
the reservoir site. The creation of a substantial reservoir 
without provision for hunting is likely to cause significant 
adverse impacts on waterfowl values in nearby wetlands. 
Waterfowl will use the reservoir, the availability of 
recreational hunting opportunities will substantially 
decrease, and the hunters who maintain and manage much of the 
Central Valley wetlands critical to the waterfowl populations 
will reduce or eliminate their support for wetlands habitat. 
For evidence of the nature and extent of the potential 
impacts, please refer to the San Luis Reservoir experience. 

2. Inadequate Alternatives Analysis 

A major defect in the document is that it fails to adequately 
address the alternative of a larger storage facility to 
operate in conjunction with other water purveyors. Both CCWD 
and others need more downstream water storage. At minimum the 
Los Vaqueros facility should be designed to allow expansion 
without the likely cumulative impacts future demands will 
place on the environemnt with new reserviors. 



24-2 



5-145 

M.V' Ml. |li.ilili> Hlxil 
Siiiic 1X1) 

I .ifwrlu VK <M'>I>' 
fl •>|(l^K.1 IJlf, 



RECEIVED 
MAY 1 2 1992 



t^ ^ Y — S 



T u 



S : «» 



© S 



Mr. John Gregg 
May 12, 1992 
Page 2 





Wo feel there are also significant benefits associated with the 
project that are deserving of praise. Environmental benefits of 
the project are too often overlooked when they should be considered 
as offsets to adverse impacts where possible. Benefits of the Los 
Vaqueros project include fish screening and operational 
flexibility. Some of the project diversions will be screened. All 
present diversions are unscreened. Therefore, any new fish screens 
will create a fishery benefit in the surrounding area. This 
benefit would be further enhanced if all diversions were to be 
effectively screened. 

The basic concept of Los Vaqueros creates an operational 
flexibility for water quality and supply purposes. This same 
flexibility can serve to benefit fisheries as pumping rates can be 
adjusted to accommodate special fishery needs in the Delta. 

Thank you for the opportunity to submit these comments. 

SiAl:erel> 



J 



2A 




John L. Winther 
President 

JLWtkf 



5-146 



Response to Comments of Delta Wetlands 



24-1. Waterfowl use of the reservoir and its effects on use of nearby privately managed wetlands was 
recognized in the Stage 1 EIR for the Los Vaqueros/Kellogg project. The proposed recreation 
plan for the reservoir includes recreational boating as an encouraged use. Experience at nearby 
Bethany Reservoir indicates that boating use will be adequate to discourage large accumulations 
of waterfowl on the Los Vaqueros Reservoir. At Bethany, waterfowl concentrated in large numbers 
until boat ramps were installed. CCWD wants to discourage large concentrations of waterfowl to 
prevent indirect effects on hunting opportunities at neighboring wetlands. 

If recreational use does not adequately discourage waterfowl concentration, CCWD will implement 
additional measures as defined in consultation with DFG and USFWS. 

24-2. CCWD undertooi< substantial efforts to include other participants In the Los Vaqueros Project and 
Incurred delays and expense in doing so. No other agency chose to participate in the Los 
Vaqueros Project. CCWD does not have sufficient funding nor a demonstrated need to construct 
a larger or expandable facility at this time. See also response to comment 2-6. 

24-3. Comment noted. CCWD concurs that the Los Vaqueros Project could provide benefits to fish and 
wildlife resources. The biological assessment for the Los Vaqueros Project contains a thorough 
discussion of existing losses of special-status fish species at CCWD's existing intal<e facility. The 
biological assessment concludes that screening that intal<e would be costly and ineffective. 
However, the CVP Improvement Act requires Rocl< Slough to be screened. 

24-4. Comment noted. 



flesponse to Comments of 0«/fa Wetlands 

5-147 







Mr John S . Gregg 
Program Manager 
Los Vaqueros Project 
P.O. Box 4121 
Concord, CA 94524 



Sierra Club 
San Francisco Bay Chapter 

Slh~ COLLIX.K A\KMi; • OAKLAND. CALIIOKMA Vi'ilK-NI i 
THLKI'HONK t10-65.^-M2~ 

ALAMIDA C(")l MT • COM KA COSTA • MaKIN • S\\ KKWCISCO 

3 May 1992 



LETTER NO. 25 



de-. 

'-' ACXLV 



RE: 



EIR/EIS for Los Vaqueros Project 



Dear Mr. Gregg: 

We have reviewed the Draft Stage #2 EIR/EIS for the Los Vaqueros 
and offer the following comments concerning the proposed project. 

Buildout Populations 

The EIR/EIS makes assumptions regarding buildout in the CCWD SOI 
and makes statements regarding relationship to other potential 
water districts in the east county for the future. The EIR/EIS 
also assumes that a certain amount of growth will occur within the 
east county without addressing the location of that growth any 
further than by assuming it will occur within the areas identified 
by the County General Plan. 

We think that this approach is too simplistic. The construction of 
what will be perceived as an expansion of water supply for CCWD 
will attract growth in an area which is already identified as a 
major growth area of the county. The EIR/EIS does not adequately 
dismiss the possibility of CCWD becoming the major water purveyor 
in this region and the ways in which that would affect future 
growth. The general plan seems to have identified some areas for 
growth, but it is not clear that they were based on the assumption 
that the reservoir would be built or that Vasco road would be 
relocated. The potential growth in the east county and its impact 
on the environment throughout the project area on roads, 
recreation, wildlife, 'and future utilities should be better 
addressed. Stating that a supplemental water supply would be 
needed in event of expansion (p 17-1) is not an adequate response 
to the potential growth induced by the proximity of the new 
reservoir and the proposed road improvements which are listed as 
mitigation measures since it delays environmental impact analysis 
rather than examining cumulative effects which may affect the 
project now. 

Growth could well occur along the County Line Alignment (Modified) 
road (p 12-24) . The proposal that Contra Costa and Alameda 
Counties ' could restrict access to the roadway and could regulate 
parcel subdivision along the alignment', does not adequately 
address the issue of potential growth along the new road in a 
sensitive wildlife area. PprPIVPn 

MAY 1 2 1P97 



25-2 



5-148 



Made fioTi recycwo mate'ia's 



Los Vaqueros EIR/EIS 
Transportation 



Sierra Club Response - p 2 



Aside from the statement (p 13-3) that 'the expected increase in 
traffic volumes is consistent with the increase in land use 
development projected in the Tri-Delta Transit service area and the 
Livermore/Pleasanton area', there is not an indication of how 
projected traffic patterns were developed or whether they are 
reasonable. Three factors make the projected figures suspect. 
First, the impact of using Vasco Road as a corridor to connect with 
proposed BART facilities was ignored due to lack of hard 
projections. There will be some impact regardless of whether the 
projections can be verified now or not. Second, the potential 
impact of the proposed airport is not included. This could 
radically alter not only transportation, but entire growth patterns 
as well. Third, it has been demonstrated time and again that 
growth begets growth. Improvement of roads and other 
infrastructure will encourage additional growth. 

Reference was made to allowing cattle crossings on the proposed 
County Line Alignment (Modified) road. It was not at all clear 
whether this was intended to be grade crossings or special 
under/over passes. These will have an impact on the level of 
service for the proposed road. 

If the Level of Service of the proposed County Line Alignment 
(Modified) road is kept too low, it will have an impact of not 
providing adequate service and creating delays at various places 
along the road. This will be especially true if cattle crossings 
are grade crossings. If the level of service is too low, there 
will be interest at some point in increasing the level of service, 
requiring additional construction in the already sensitive area. 
This would not be acceptable. 

On the other hand, if the level of service is too high, it will be 
an encouragement for additional growth in the area and an 
encouragement for the developers of the proposed toll road to try 
and use it. If the County Line Alignment (Modified) road is built, 
we must insist that the level of service and alignment be carefully 
analyzed to preclude additional construction activities in the area 
in years to come. 

Wildlife 

There are many sensitive species located in the Kellogg Creek 
Watershed. The existing ecosystem would be disturbed, if not 
destroyed by construction of either of the two reservoirs. There 
is not enough known about some of these species to know whether 
they would recover after construction of the reservoir, if built. 
The loss or reduction in numbers of even one species can have a 
cumulative effect on the other species in the area. 



25-6 



25-7 



25-8 



25-9 



25-10 



5-149 



Los Vaqueros EIR/EIS Sierra Club Response - p 3 

Recreation is listed as a benefit to the overall project. However, 
the effects of allowing recreation within the watershed may, in 25- 
fact, provide additional stress on any species which do remain 
after any construction allowed. 

In chapter 8 there is discussion of conducting surveys at the site 
to determine the mitigation requirements for construction, if 
either of the reservoir sites is chosen. More information is 
needed before the acceptance of the EIR/EIS and before a reservoir 
alternative is selected. 

There are several mitigation measures mentioned with regard to 
construction activities and employee conduct on-site (p 8-40 ff). 
There is no apparent safeguard measure to ensure that these 
measures would be followed. 

Desalination Plant 

There does not appear to be an analysis of the impact of 
discharging 5-25 mgd of brine (with estimated 3,500 mg/1 of TDS and 
1200 mg/1 of chlorides) into Suisun Bay. There is no analysis of 
the impact which that water will have on the overall salinity of 
the Bay when mixed with flows in the Bay. To state that this 
impact will be reviewed later is to deny the opportunity to fully 
assess this alternative now. 

Generally, there are too many areas where the EIR/EIS has relied on 
previous reports which may not be specific enough regarding 
changing conditions in the east county area. The EIR/EIS assumes 
that growth will occur in identified regions rather than 
acknowledging that the project may be a precipitating factor in the 
future growth of the region. There are several areas where more 
study is required to provide information to allow informed decision 
making, but these areas have been dismissed as requiring study 
' after the fact ' . 



Regards , 



Paul A. Colbert 

Co-Chair, Water Subcommittee 



5-150 



Response to Comments of the Sienv Club - San Francisco Chapter 

25-1. As indicated on page 18-1 of the EIR/EIS, the approach used for evaluating cumulative impacts 
is a combination of the approaches recommerxJed in the State CEQA Guidelines (14 COR 
151301b]). 

25-2. As indicated in the Stage 2 EIR/EIS, the project has t>een designed as a water quality and 
reiiability project. The project would not sUlow CCWD access to any additional water supplies, nor 
would the project facilitate distribution of water supplies into areas r>ot currently serviced by 
CCWD. 

Contra Costa County and the municipalities within the east county area are responsible for 
regulatir>g growth within the project area. CCWD water system improvements would correlate with 
the growth rates and levels of service planned for and allowed by various city and county planning 
agencies. Other than a small arrxxjnt of growth that could be stimulated because of the additional 
recreation opportunities presented by the project, growth that would occur with Implementation 
of the project would be similar to growth that would occur under no-action conditions. The Los 
Vaqueros Project would, therefore, ncH affect growth assumptions contained In the general plan. 

25-3. Project-related growth would lii<ely be limited to that described above under response to comment 
25-2. The Stage 2 EIR/EIS does, however, evaluate the contribution of the project to cumulative 
and growth-related impacts in the region. 

25-4. As stated on page 1 7-1 of the Stage 2 EIR/EIS, expanding water service into the east county area 
is not a component of the Los Vaqueros Project. Should CCWD decide at some point in the 
future to expand water service into this area, additional environmental analysis under CEQA would 
be required. 

The growth potentially induced by the reservoir is discussed on pages 18-16 and 18-17 of the 
Stage 2 EIR/EIS. Although relocation of Vasco Road was listed as a mitigation measure in the 
Stage 1 EIR for the Los Vaqueros/Kellogg Project, it was the subject of a subsequent EIR that fully 
evaluated tfte growth-irxjucing effects of relocating the roadway and several other utilities from the 
Kellogg Creel< watershed. 

25-5. Counties and cities in the vicinity of the road relocation have no plans for growth in the road 
relocation corridor. Most of the corridor is zoned and designated for large-parcel agricultural uses 
arxi is outside the urban limit lir>e in Contra Costa County. 

Some minor growth coukJ occur along tt>e relocated Vasco Road. Considering the rugged ten^in 
along the County Line AiignnDent (Modified), less suitable acreage is available for development 
along the relocated roadway than along the existing Vasco Road. Contra Costa and Alan'>eda 
Counties would be responsible for managing growth along the relocation corridor. 

The Stage 2 EIR/EIS includes mitigation that CCWD believes would reduce the impacts of the 
project on terrestrial species to less-than-significant levels. These mitigation measures were 
developed through communication with DFQ and USFWS that has taken place regularly since 
1988. CCV^ has completed formal consultation with both the rJational Marine Fisheries Services 
and USFWS and is continuing to consult with DFG on its responsibilities towards special-status 
species. 



R»spon$0 to Comwnta of tfw Siem Club ■ San Fnncitco Chapter 

5-151 



25-6. As stated on page 13-3 of the Stage 2 EIR/EIS, future year travel patterns were based on 
transportation data from the draft Contra Costa County General Plan, the Oakley General Plan, the 
Uvermore Community General Plan Circulation Element, the Uvermore l-580/Route 84 traffic study 
draft report, and the route concept report for 1-580. These studies contain the most current data 
available for the project area. Specific information Is not yet available for the proposed airport of 
BART facilities and therefore cannot be included in the analysis. CCWD t>elieves that the 
Information contained in the EIR/EIS Is appropriate for analyzing the impacts of the \jos Vaqueros 
Project 

25-7. Cattle crossings would be culverts or box-culverts and would have no effect on traffic flow. 

25-8. CCWD is obligated to replace the existing road, following cun-ent AJameda and Contra Costa 
County road design standards. Growth and traffic projections indicate that the Vasco Road 
corridor will need to be upgraded to four lanes In the future to adequately handle projected traffic 
volumes. The relocation of Vasco Road does not substantially alter this need, which is created 
by regional growth pattems. 

25-9. See response to comment 25-8 above. CCWD Is designing the relocated new roadway to be 
generally similar to the existing Vasco Road with some additional safety improvements, including 
8-foot-wide paved shoulders, climbing lanes, increased curve radii, and increased lane widths. 

25-1 0. CCWD has conducted extensive biological studies of the Kellogg Creek watershed since 1 987 and 
has communicated extensively with DFG and USFWS to identify impacts and develop measures 
to reduce or eliminate impacts on wildlife and plant species. As nnandated in CCWD Board 
Resolution 88-45, CCWD has sought to reduce all significant impacts to tess-than-significant levels. 
CCWD believes thiat its previous studies, the Stage 2 EIR/EIS, and the biological assessment 
provide an adequate basis for analyzing impacts and developing mitigation measures. 

25-1 1 . CCWD recognizes that recreation activities could be the source of additional impacts on sensitive 
wildlife and plant species. The Stage 2 EIR/EIS includes analyses of the potential effects of the 
conceptual recreation plan on these species, and recommends mitigation measures for significant 
impacts. 

25-12. The additional surveys cited in this comment refer to mitigation measure 8-1 in the Stage 2 
EIR/EIS, which requires CCWD to conduct surveys on small areas (about 20 acres) that have not 
prevkxjsly been surveyed because of lack of access and to mitigate any additional impacts as 
identified In the rest of the wildlife mitigation section. Given tiiat CCWD has conducted surveys 
over thousands of acres in the project area, the Information developed through these surveys will 
not provide substantial new information that may affect the selection of an alternative. 

25-13. CCWD has developed constructkxi rrxxiitoring programs for each project component. Qualified 
nxx^ors will be onslte to ensure that Incidental constructkxi Impacts are avoided and to monitor 
employee conduct. A qualified archeologist will be employed to monitor excavation activities in 
areas that could contain subsurface cultural resources as appropriate. The archeologist will 
ensure that all proper measures are taken In the event that cultural resources are discovered. 

The CCWD Board of Directors must adopt a mitigation rrxxiltoring and reporting plan at tt>e time 
the project is approved. 

25-1 4. The impacts of dischiarging brine waste from the desalinatkxi plant into Suisun Bay are discussed 
on page 5-35 of the Stage 2 EIR/EIS. Discharges of thie brine waste, even after dilution in Suisun 
Bay, may exceed basin plan objectives for scilinity and k>ns and, therefore, would represent a 
significant impact. If this project were to be proposed and permits pursued, modeling would need 



Response to Comments of the Sierra Club ■ San Frmncitco Chapter 

5-152 



to be performed to determine appropriate dilution requirement, aid in design of the plant's 
wastewater diffuser, and determine wfiether treatment of tfie brine is required and feasible. 

25-15. See response to comment 25-2 above. 



Response to Comments of the Sierra Club - San Franciscxi Chapter 

5-153 



LETTER NO. 26 



KE N ETE Ckl/ 0*5^ WlNDTOttER. INC 

^^ ^^ Oiif Kai-'tT Pla/.i. Siiiii- C)75 

U. S.WINDPOWER y^r s;.:;:^r'o^t " 

KAX: 510-8V:il553 

VIA CERTIFIED MAIL 
RETURN RECEIPT REQUESTED 



April 16, 1992 



Mr. John S. Gregg 
Project Manager 
Los Vaqueros Project 
Post Office Box 4121 
Concord, California 94524 

RE: Comment Letter - Draft Stage H EIR/EIS 
("EIR") for the Los Vaqueros Project 

Dear Mr. Gregg: 

We are extremely concerned at the absence in the EIR of any discussion of: (1) the impact 
of the Project on the wind resource, contrary to the specific terms of the March 1991 Project 
Scoping Report, and (2) several additional issues raised in our April 16, 1990 and June 21, 
1991 letters to you. More specifically: 

L Wind Resource . In our April 16, 1990 letter we indicated that the EIR needed to 
analyze the impact on wind resources of changes in topography caused by the Project. 
Pages 5-51, 5-66 and 5-67 of the Scoping Report stated that you would conduct this 
analysis in the EIR. We did not see any such discussion in the EIR, nor did we see 
any discussion of the reasons for its exclusion. 

Not only is the EIR inadequate without such analysis, but it will be insufficient to 
undertake such analysis at this point and include it only in the Final EIR. CEQA 
§2 1092. 1 requires recirculation of the draft EIR whenever significant new information 
is added to a report or where there are substantial changes to the initial draft (see, 
e.g. . Sutter Sensible Planning v. Sutter County Board (1981), 122 Cal. App. 3d 813). 

In light of your commitment to undertake the analysis in the Scoping Report, we 
simply fail to understand why you have apparently concluded, without any analysis, 
that the impact of the Project on the wind resource is so insignificant as to warrant no 
discussion. 

5.154 APR 2 mi 



26-1 



Mr. John S. Gregg 
April 16, 1992 
Page 2 

2. Other Impacts . In order to evaluate the effect of the Project on our existing and 
potential wind projects, our April 16, 1990 letter indicated various other impacts of 
the Project which would require compensation such as removal or relocation of 
existing facilities, lost future development values and disruption during construction. 26-2 
We also expressed concerns about recreational use and the need for U.S. Windpower 
to have the continued and undisturbed use of the properties under its wind easements. 
Though the Scoping Report indicated that the draft EIR would assess these potential 
land use conflicts (see pages 5-50, 5-51, 5-55, 5-56 and 5-67), we did not see this 
analysis in the EIR apart from a 3-sentence "Redevelopment Guideline" for 
recreational use on page A- 14 of the EIR Technical Report, which in no way 26-3 
describes how public access to these properties will be prevented. Further, we did 
not see any analysis of the Project's potential reduction of County tax revenues due 
to the negative impact on wind energy facilities, as requested in our June 21, 1991 
letter. 

We would appreciate meeting with you immediately to understand why you have ignored our 
concerns. 




JJE:slm 



5-155 



Response to Comments of Kenetech/U.S. Windpower 



26-1. CCWD originally intended to indude information In the draft EIR/EiS regarding the resen/oir's 
effect. If any. on wind resources, but could not obtain such Information from Kenetech/U.S. 
Windpower. CCWD subsequently contracted with San Jose State University to conduct the 
necessary wind studies. Inforrriatbn acquired from three ar^emometers was used, and data were 
Input into a mathematical computer model and the reservoir effects on wind velocity, direction, and 
frequency were modeled. 

The results of these studies showed that daily average windspeeds would be slightly higher 
(apfxoximately 2% of the daily mean windspeed or 0.2-0.4 mph) to the east and northeast of the 
reservoir, benefitting wind turbines located In this area. The model also predicted a smaller region 
In which windspeeds toward the southeast, southwest, and northwest would be decreased by 
approximately 0.1-0.07 mph. Given the accuracy of anenxKnetry and the magnitude of spatial 
variations in interannual mean windspeeds typical of the Altanx>nt Pass area, the actual decrease 
may be undetectable. 

Overall, the wind studies indicate that the reservoir would either have an undetectable effect or 
slightly positive effect on wind velocity. These small changes would not produce any detectable 
physical effect on the environment. 

Because of the negligible effect the reservoir would have on wirxj velocity and direction, CCWD 
does not believe that the results of this wind study present significant new information. 

26-2. Removal or relocation of existing facilities and construction-related impacts were analyzed and 
found to be less than significant in the draft and final EIR for the Vasco Road and Utility Relocation 
Project. These discussions appear on pages 4.7-9 to 4.7-10 of the draft EIR and pages 3-160 to 
3-164 of the final EIR. The information on the referenced pages is hereby incorporated into this 
response. No new information has been obtained that would require any change in these 
conclusions. 

CCWD plans, however, to compensate wind power companies for removal, relocation, or any 
other compensable losses related to relocating watershed utilities and Vasco Road. 

CCWD does not plan to acquire the rights to develop wind power because such rights are 
expensive, and the reasonable exercise of these rights is not incompatitjie with watershed 
protection. Therefore, CCWD's purchase of the underlying lands would not affect the ability of the 
wind power companies to expand operations into areas for which they already own development 
rights. If further expansion is pursued by the wind power companies, their plans would be subject 
to approval by local jurisdictions. 

As stated in the Stage 2 EIR/EIS. CCWD does not plan to locate recreation facilities in windfarm 
areas and. as indicated on page A-14 of the Stage 2 EIR/EIS Technical Report, will restrict access 
to these areas. Because this recreation planning guideline will be implemented in locating and 
designing recreation facilities and managing use areas, impacts are not anticipated. Although 
CCWD cannot now determine specific measures to restrict access to windfarm areas because 
such measures necessarily depend on the nature and location of the recreation facilities, such 
nr>easures could include fencing, patrolling, and posting appropriate signs. 

26-3. As described in response to comment 26-1, effects on wirxJ pattems In the project area are 
negligible and may be undetectable. CCWD is not aware of any information that Indicates that the 
proposed action would meaningfully affect the county tax base. 



Response to Comments of Kenetech/U.S. Windpower 

5-156 



cc o I i 3 i ^ ^ 
Pacific Gas and Electric Company 



123 Mission Streel 

San Francisco, CA 94106 

415/9727000 



LETTER NO. 27 

^ V > ■rxiT .■ 
J se- 



lf' 



May 1, 1992 



Mr. John S. Gregg 
Program Manager 
Los Vatjueros Project 
P.O. Box 4121 
Concord, CA 94524 

RE I COMMENTS ON DRAFT STAGE 2 EZR/EIS FOR THE LOS VAQUEROS PROJECT 

Dear Mr. Gregg: 

PG&E has reviewed the Draft Stage 2 BIR/EIS for the Los Vagueros Project. 
We would like to thank you for your consideration of our comments and 
questions regarding the Administrative DEIR/EIS. He have the following 
comments on the Draft Stage 2 EIR/EIS: 

General Comments 

PG&E has conducted a feasibility study for supplying power at the Camino 
Diablo transfer reservoir site only. It is indicated in the Draft EIR/EIS 
that this site is the preferred alternative. If this does not becotne the 
approved alternative it will be necessary to conduct a feasibility study 
for providing service to another site. 

It is imperative that PG&E receive formal notice of the power supply 
option required for the transfer pumping plant so we cam meet your project 
schedule. If you select service from our existing 230kV transmission line 
to a substation at the transfer pump site, we must cononence filing 
immediately with the California Public Utilities Commission (CPOC) for a 
Certificate of Public Convenience and Necessity (CPCN) . One requirement 
of the CPCN application is an environmental review specifically for the 
new electric transmission line. Please inform PG&E as soon as possible 
which power supply option has been selected for the transfer reservoir. 



A number of references are made to the PG&E Hill Transfer Reservoir Site 
Please clarify why PG&E is referenced at this site. 



27-1 



27-2 



•] 



Impacts associated with the electric transmission facilities are dependant 
upon the type and the location of the facilities. For example, the 
discussion of potential impacts in the Visual Resources section describes 
where the transmission lines would be located with various configurations. 
The discussion of impacts is purely speculative since PG&E cannot verify 
the adequacy of these locations without further study. Therefore, PG&E 
cannot assume responsibility that our facilities have been adequately 
described in the DEIR/EIS. 

Specific Comments 

Page 7-16 

The impact discussion of the electric transmission line corridor indicates 
that 0.8 acre will be affected. This is apparently referring to the new 
transmission line. Please clarify whether both the new electric 
transmission line and the relocated transmission line impact 0.8 acre. 



27-3 



27-4 



27-5 



5-157 



RECEIVED 

MAY - 7 1992 



Mr. John S. Gregg 
May 1, 1992 
Page 2 



Page 7-19 

The impact discussion for the electric transmission line relocation also 
indicates that 0.8 acre will be affected. Please clarify whether both the 
new electric transmission line and the relocated transmission line impact 
0.8 acre. 



Page 7-15 Table 7-1 

Under the headings "Electric Transmission Line" and 
Pipeline," the word Relocation should be added for clarity, 
the new service falls in this table. 



"Natural Gas 
Clarify where 



Page 7-34 Table 7-6 

The reference to PGSE Transmission Line-Old River Alignment was not 

deleted as previously reqpjested. Please delete. 

Page 20-2 Table 20-1 

Under the CPUC heading. Certificate of Public Convenience and Necessity 
should be followed with (CPCN) . The information under Agency Authority is 
irrelevant. The CPUC issues CPCNs for electric lines of 200kV and above 
under its General Order No. 131-C. Whether the service area is 
noncontiguous or the cost of service expansion is high is irrelevant. 
Please revise accordingly. Please revise language in the last column as 
follows: The 230kV electrical Interconnection for project operational 
power, if it is determined that a CPCN la required . 

Page 20-8 Table 20-1 

The language under the heading Agency Authority in the PG&E column should 
be revised as follows: PG&E grants permission for activities undertaOcen 
within PG&E Rights-of-Hay and agrees to relocate PG&E facilities. The 
language under the last column should be revised as follows: Construction 
of roadways or facilities that cross or parallel PG&E utility Rights-of- 
Way and relocation of PG&E facilities. 

Page 20-10 

The information under California Public Utilities Commission is incorrect. 
PG&E is not required to file an advice letter with the CPUC. Notification 
of construction must be filed with the safety branch 30 days prior to 
construction. A CPCN is required if electric lines exceed 200kV. 

Mitigation Measures 

The Draft EIR/EIS does not address which mitigation measures are specific 
to PG&E. We understand that construction related mitigation is applicable 
to PG&E, however, it would be helpful for us and for monitoring purposes 
if PG&E were specifically named. We anticipate that communication will 
take place when the exact alignment for the new electric transmission line 
is finalized. Prior to construction we will need to know which specific 
mitigation is applicable and who is responsible. 



5-158 



Mr. John S. Gregg 
May 1, 1992 
Page 3 



Thank you for the opportunity to provide comments on this document, 
Please contact me at 415-973-5769 if you have any questions. 



Sincerely, 

Elisabeth A. Brokaw 
Planning Analyst 

LMB(3-5432) 



5-159 



Response to Comments of the Pacific Gas and Electric Company 



27-1 . Comment noted. 

27-2. The staff-preferred option for power supply is for dedicated service to be provided from PG&E's 
existing Brentwood substation on Sellers Avenue to the Transfer Pumping Plant within PG&E's 
franchise area along Sellers Avenue, Paine Avenue, and Walnut Boulevard. A transformer would 
be installed at the substation and a 21 -kV service line would be extended first via an underground 
line along Sellers Avenue and then on an existing overhead pole line along the other two 
thoroughfares. The overhead line would be reconstructed to accommodate both the existing and 
transfer pumping plant circuits. Because the line would be underground and along existing pole 
lines, and because the areas through which the line would pass are not environmentally sensitive, 
no environmental impacts are anticipated. 

27-3. A PG&E transmission tower is located at the apex of the hill. CCWD has used this terminology 
to refer to the site because the hill is otherwise unnamed and has no other distinguishing features. 

27-4. CCWD made assumptions regarding the specific electric transmission facilities that would be 
constructed to serve the Los Vaqueros Project. Wherever appropriate, CCWD made worst-case 
assumptions to ensure that the impacts of new and relocated PG&E facilities would be fully 
disclosed in the Stage 2 EIR/EIS. Should the location of facilities change in the future to the 
extent that new impacts could occur, CCWD would be responsible for any required review under 
CEQA. 

27-5. The 0.08 acre of annual grassland affected refers to the impact of the relocated electric 
transmission line. Annual grasslands are considered a common plant community and the effects 
of the project on this community would not be considered a significant impact. 

27-6. See response to comment 27-5. The impact acreage for the new transmission line is combined 
with the acreage affected by the alternate Old River pipelines. These acreages are summarized 
in Table 7-2 of the Stage 2 EIR/EIS and are discussed for each project alternative on pages 7-22 
through 7-26. 

27-7. Comment noted. The final EIR/EIS has t>een modified to reflect this change. 

27-8. Comment noted. The final EIR/EIS has been modified to reflect this change. 

27-9. Comment noted. The final EIR/EIS has been modified to reflect this change. 

27-10. Comment noted. The final EIR/EIS has t>een modified to reflect this change. 

27-1 1 . Comment noted. The final EIR/EIS has t)een modified to reflect this change. 

27-12. CCWD would be responsible for all mitigation measures for relocating the natural gas pipelines 
and the electric transmission line unless this responsibility is contractually assigned to PG&E. 



Response to Comments of the Pacific Gas and Electric Company 

5-160 



SENT BY:Xerox Telecopier 7021 ; 5-11-92 ; 8:27PM ; THE REPRO EXPRESS- 



LETTER NO. 28 







EAST BAY CHAPTER 

Alameda & Contra Costa Counties 
California Native Plant Society 



May 11,1992 



Mr. Gan' Darling 
Contra Costa Water District 
P.O. Box 4121 
Concord, California 94524 

Re: CCWD Draft Stage 2 DEIR for the Los Vaqueros Project 
SCH #91063072 



Dear Mr. Dariing: 

As you may know, the California Native Plant Society (CNPS) is a statewide organization 
of professionals and laypeoplc dedicated to the enjoyment and preservation of California 
native plant resources. The East Bay Chapter of CNPS (EBCNPS) is a 1,400 member 
chapter whose area of concern is Contra Costa and Alameda counties. Our Conservation 
Committee has formally reached consensus on this issue and have received Chapter Board 
approval of that consensus. We appreciate the care with which our first comments on the 
Vasco Road and utilities relocation DEIR were considered and, as appropriate, incorporated 
in this document. We believe our comments on the stage 2 DEIR will provide constructive 
criticism of the Los Vaqueros Project Environmental Review process. 

EBCNPS reviewed the DEIR in three areas relating to vegetation -- 1. Identification of the 
resources and their value; 2. Identification of impacts and their significance; 3. Mitigations 
and their effectiveness in reducing impacts to less than significant. In the area of resource 
identification and valuation this DEIR is exemplary. With the reservations expressed 
within the DEIR itself we consider this aspect of the DEIR adequate to proceed to impact 
assessment and mitigation. 

Identification of impacts to these resources is thorough with one serious exception. 
Should not the specific impacts of possible recreational resource 
development be identified, assessed and mitigated within this document? 
The potential for conflicts between preservation, enhancement, and restoration goals is real, 
until these potential conflicts are identified and mitigated is not this DEIR 
incomplete and inadequate? Listing this need under the environmental commitments 
section does not meet the need for CEQA mandated public review. 

Mitigations and their effectiveness require a more complete response. But first and 
foremost; why does not this DEIR contain specific vegetation planning and 
management recommendations to realize CCWD policy requiring "that lands 
be managed to maintain or enhance existing resource values" (7<17)? Special 
vegetation and specific land area zonings provided with short and long term management 



28-1 



28-2 



28-3 






5-161 



Dedicated to the Preservation 
OF California Native Flora 



SENT BY:Xerox Telecopier 7021 : 5-11-92 : 6:27PM ; THE REPRO EXPRESS- 798U52:« 3 



programs are basic tools to realize this excellent policy. This approach would prevent or 
reduce conflicts between differing land utilization needs. Should not special 
vegetation land area zonings be mapped, identifving areas to be preserved, 
enhanced, restored or created and the commitment to their long term 
monitoring and reservation in the form of management plans be contained 
in this DEIR? 

Mitigations, as the DEIR notes, involving enhancement, restoration or creation of habitats 
for species or communities are largely experimental or even unattempted to date. CNPS 
has developed a lively skepticism of such mitigations based on almost uniformly poor 
success rates. However, the standards and techniques for establishing and the monitoring 
included in the DEIR are to best current standards. These standards will demand the very 
best skills available to achieve a measure or success in satisfying mitigation needs. 
Should not all enhancement, restoration, creation or purchase mitigation 
strategies be specifically under the control of a land managing body (i.e. 
Nature Conservancy) or a private consulting group contracting with CCWD 
with proven experience in this area of special skills and given with 
sufficient financial resources to achieve such strategies? This would be a 
refinement of the strategy on Page 7 - 43 which names CCWI) and EBRPD as possible 
agencies. While both are excellent resource managers, the special skills and consistent 
budget availability to realize these mitigation strategies would need careful augmentation 
and modification of existing agency structures. 

Out of kind/like-value creations as defined in this DEIR do not reduce or mirigate impacts. 
They are correctiy listed as compensations under the environmental commitments section. 
Should not the 2:1 purchase and protection of nearby like communities to 
those being lost be the preferred compensation? Replacing "apples with 
oranges" docs not mitigate or compensate adequately. 

7 - 16 on 7 - 46 refers to the potential growth inducing impacts of the relocated Vasco 
Road. The mitigation proposed. Contra Cost County zoning policy, is not in the short or 
long term CCWD control, and as such is not a mitigation. Should not CCWD 
purchase lands or conservation easements parallel with the right of way, 
dedicate them to open space/preserve use except as would accomodate 
existing access? This would minimize future growth impacts. 

Finally, EBCNPS would make the plea that the CCWD would reconsider it's preferred 
alternative. We appreciate the charge CCWD has to best provide for its service area. We 
respect the seriousness with which CCWD has examined the alternatives. But Los 
Vaqueros would destroy the largest known valley oak woodlands and disrupt or destroy 
our best alkali commumries in Contra Costa County. This would be tragic for present and 
future residents of our area. We urge CCWD to reexamine the EBMUD emergency supply 
alternatives as being the most environmental sensitive. 

Thank you for considering our comments. 
Sincerely, 

David Bigham 

Local Issues Conservation Coordinator 

EBCNPS 

5-162 



Response to Comments of the East Bay Chapter of the California Native Plant Society 



28-1. Comment noted. 

28-2. CCWD has developed a conceptual recreation plan. This plan was developed taking into full 
account all sensitive resources in the Kellogg Creek watershed. In addition to avoiding sensitive 
resources, CCWD has developed recreation development guidelines, contained in Section A-2 of 
the Stage 2 EIR/EIS Technical Report, that will prevent impacts from occurring. It is important to 
note that the recreation plan has been developed at the conceptual level. CCWD is confident that 
the conceptual recreation plan could be implemented without resulting in new significant impacts 
on sensitive resources. However, if future recreation planning indicates that some sensitive 
resources may not be avoided, CCWD will prepare and circulate additional environmental 
documentation to comply with CEQA and adopt appropriate mitigation measures. 

28-3. CCWD concurs that a long-term watershed management plan is an appropriate and effective tool 
for implementing CCWD policies regarding land management. CCWD plans to prepare and adopt 
such a plan before the public is allowed access to the area. This plan will be designed to achieve 
CCWD goals regarding vegetation management and will bring together all previous environmental 
commitments made by CCWD. The plan will identify specific areas to be preserved, enhanced, 
restored, or created; and will include commitments to long-term protection of these areas. 

28-4. As noted in the Stage 2 EIR/EIS throughout the "Mitigation K/leasures" section of Chapter 7, 
"Vegetation Resources", creation of certain types of habitats would t>e experimental and uncertain. 
The mitigation programs developed in the Stage 2 EIR/EIS for wetlands and oak and riparian 
woodlands, which are included as appendices to the final Stage 2 EIR/EIS, recognize this 
uncertainty and therefore propose to mitigate impacts using proven methods. CCWD has 
conducted a multiyear study of the effects of enhancing alkali wetlands and has documented 
tremendous success with these techniques. 

CCWD will consider entering into arrangements with other land managing entities such as The 
Nature Conservancy. CCWD has met with representatives of several private nonprofit land 
managing entities during the development of the Los Vaqueros Project. However, CCWD believes 
that, with appropriate staff additions, it or the East Bay Regional Park District is capable of 
managing these sensitive resources. 

28-5. Comment noted. The mitigation program developed by CCWD includes out-of-kind/like-value 
creation combined with acquisition, enhancement, or restoration of degraded wetlands of the 
same type along with acquisition and protection of high-quality wetlands. 

28-6. CCWD believes that existing controls on growth in the area surrounding the relocated Vasco Road 
are adequate to prevent secondary impacts from occurring. CCWD concurs that this measure is 
not under Its control but believes that, consistent with Section 15091 of the State CEQA 
Guidelines, this measure is under the control of Contra Costa County and has been adopted and 
is likely to be implemented by the county. 

28-7. CCWD undertook an extensive altematives analysis process before it and Reclamation prepared 
the Stage 2 EIR/EIS. Several altematives that relied on an emergency supply from East Bay 
Municipal Utility District (EBMUD) are considered in CCWD's 404(b)(1) altematives analysis. 
CCWD did consider alternatives that included an EBMUD emergency supply component in the 
State 2 EIR/EIS. Because of inadequacies in the EBMUD system, however, none of these alterna- 
tives can provide CCWD with sufficient supply to meet its identified emergency supply needs. 



Response to Comments of the East Bay Chapter of the Calitomi* Native Plant Society 

5-163 



I 

l2nZ redesign of project features. As part of CCWD's mrtigation plan, a large alkal, wetland I 

would be acquired for protection and enhancennent. 



Response to Comments of the East Bay Chapter of the ClUomie Native Plant Society 

5-164 



<3^ v3. :l.<^iS' 



|r CONTRA COSTA 
COUNCIL 



One Annabel Lane, Suite 2^■i 
San Ramon, CA 94583 
Phone (510)8b6-6bbb 
Fax; (510)866-8647 

May 12, 1992 



LETTER NO. 29 



ii 

>usan McNutty Rainey 

3(MrtJ of D'fecfofs 
Zenlrat Contra Costa 
Santtary Disttict 

mmsdM* Past Pmsldeni 
rdward F Oel Baccaro 

VesxJenf 

Cirus Corporation 

=n> VIo* PmsWeni 

=ric Hatiettlne 

iassefttne Best 
Nm vm President 

'•tmar Brown Madden 

4cCutchen Doyle Brown 
i Erwrsen 

nam P rMldenI 

. Mtch««4 Rogers 

Jeprtjna/ Vtce President 
iank of Amencs NT & SA 

lioa President Membership 
A Merlieting Services 

kKwtance K Mattson 

rice President 4 
Weyiona' Manager 

^rte Bank ot California 

f ice President 
^xnmunicatwns 
lames E Simmons 
Corporate Director 

Public Attain 
rosco Refining Company 

Eiecuttve Director 
>aneLonosN>re 



Board of Directors 
Contra Costa Water District 
P. O. Box H20 
Concord, CA 94520 

RE: Conunents on Draft Stage 2 EIR/EIS 
for the Los Vaqueros Project 

Ladies and Gentlemen: 

We want to compliment the Contra Costa Water District for 
its vision and perseverance in the planning and 
preliminary design phases of the Los Vaqueros Project. 
The Contra Costa Council strongly supports the project's 
major goals of improved water supply for the 400,000 
residential customers of the District. The Council 
appreciates the opportunity to make the following 
comments on the EIR/EIS. 

First, to facilitate review of the EIR/EIS by the public, 
and to secure additional local support for the project, 
we recommend that a simple, clear executive summary be 
included. This could take the form of a matrix of 
relative ranking including costs, environmental factors 
and social concerns. We believe Jones & Stokes 
Associates did an excellent job in describing the 
specific impacts of each alternative throughout the 
document, and that they would be well suited to prepare 
the executive summary. 

Second, the EIR/EIS should, as many expected, analyze 
alternatives for a larger reservoir. Whether or not a 
larger project is immediately viable, this analysis 
should be done now so as not to lose the opportunity to 
analyze these alternatives in a cost effective manner, 
and to mitigate or preclude delays should other water 
agencies eventually be persuaded to join in the project. 
The work supported earlier by the East Bay Municipal 
Utility District could help establish the maximum storage 
volume that could be implemented without additional 
significant environmental effects. PPrFIVEO 



29-1 



29-2 



5-165 



MAY 1 2 1992 



Rocvrriabie ana maOe fi 



om fecyOM waste 



Finally, based on our review of the EIR/EIS for both the 
Los Vaqueros and Kellogg reservoir sites, we believe that 
a unique opportunity to provide vital storage capacity 
for Northern California urban water system needs may be 
irrevocably lost should this project go forward at the 
capacity currently planned. Expansion of surface water 
storage capacity at these sites could be accomplished 
with very minimal additional environmental impact. 
Moreover, a reservoir with greater capacity would be much 
more cost effective (Los Vaqueros is $4,400/acre foot of 
capacity) and less of a financial burden to Contra Costa 
County ratepayers . 

Again, the Contra Costa Council supports the Los Vaqueros 
Project concept and hopes to see it developed to its full 
potential as soon as possible. If we can be of 
assistance in any way, please call either Pam Reed, Chair 
of the Council's Water Task Force at (510) 295-3304 or 
Diane Longshore, Executive Director of the Council at 
(510) 866-6666. 




ely. 



Contra Costa Council 
Eric Hasseltine 
President 



EH: im 
ccwdlv 

cc: Douglas P. Wheeler 
David N. Kennedy 
Lyle Hoag 
Jorge Carrasco 
Lori Griggs 



5-166 



Response to Comments of the Contra Costa Council 



29-1 . CCWD has undertaken considerable efforts beyond the environmental review process to promote 
public involvement and education regarding the Los Vaqueros Project and will continue to do so. 
Although a concise executive summary may have been useful had it been available during review 
of the draft Stage 2 EIR/EIS, CCWD believes, given the relatively moderate public interest in the 
project as evidenced by low attendance at public hearings and the low number of comments 
received, that its continuing public information efforts are appropriate. 

29-2. As described in the Stage 2 EIR/EIS and Appendix B of CCWD's Section 404(b)(1) alternatives 
analysis, CCWD has expended considerable effort to facilitate other agencies' participation in the 
Los Vaqueros Project since 1985. Benefits to CCWD, other participants, and the environment 
could be realized from a joint-participation project. CCWD has encouraged and led discussions 
of regional water management issues and believes that efforts to solicit participation have been 
extended to all potentially interested parties at the expense of delaying the planning, study, and 
implementation of the proposed project. All other agencies declined to participate in the Los 
Vaqueros Project. 

29-3. CCWD and Reclamation included the Kellogg Reservoir as an alternative in the Stage 2 EIR/EIS. 
Although implementing the proposed project would not physically preclude the development of 
the Kellogg Reservoir, CCWD is unable to fund such an additional project and will be unat>le to 
do so for the foreseeable future. In addition, the Kellogg Reservoir Alternative would have to 
overcome numerous environmental regulatory issues. The reservoir site contains many acres of 
wetland habitat and numerous special-status plant species populations and provides habitat for 
the San Joaquin kit fox. Therefore, CCWD and Reclamation do not believe that analyzing the 
development of the Kellogg Reservoir site is appropriate at this time. 

29-4. Comment noted. 



Response io Comments of the Contra Costa Council 

5-167 



. LETTER NO. 30 

C(ifJ 111 so ^^^ 



C WELL RANG H 



J> r o i e c I 

May 8, 1992 

Mr. John S. Gregg 
Program Manager 
Los Vaqueros Project 
P.O. Box 4121 
Concord, CA 94524 

Re: Draft Stage 2 EIR/EIS For 
The Los Vaqueros Project 

Dear Mr. Gregg: 

Thank you for the opportunity to comment on the Contra Costa 
Water District's (CCWD) EIR/EIS for the proposed Los Vaqueros 
Project. Based on our review of the Draft EIR/EIS we have the 
following comments. 

1. The Los Vaqueros Pipeline Alignment Should Be Better Defined 

CCWD has selected the Los Vaqueros Reservoir Alternative 
with a new supplemental intake at Old River No. 5 site as 
its preferred alternative. Starting on page 2-6 of the 
EIR/EIS there is a description of common facilities for the 
Los Vaqueros Reservoir alternative. The common facilities 
include the Los Vaqueros Pipeline as shown on Figure 2-2 
which would run approximately 12 miles from the Neroly 
Blending Facilities to the main dam of the Los Vaqueros 
Reservoir. The EIR/EIS does not define the exact location 
of the pipeline alignment, yet purports to evaluate 
sepecific impacts along the proposed right-of-way. Specific 
environmental and land use impacts will vary depending on 
the exact location of the pipeline. Therefore, the 
description of the pipeline alignment should be more precise 
in order to determine the exact nature of the impacts. 

2 . Alternative Alignments For The Los Vaqueros Pipeline Should 
Be Evaluated 

The Draft EIR/EIS evaluates five alternative projects, plus 
six alternate project configurations, yet fails to consider 
any alternative alignments for the Los Vaqueros Pipeline 
connecting the Los Vaqueros Reservoir with the Neroly 
Blending Facilities. Alternative alignments should be 
evaluated that would minimize the impact of the pipeline on 
existing and proposed land uses. 

5-168 RECEIVED 

3650 Mt Diablo Boulfvard. Suite 230 M&V 19 1QQ? 

Ufayenc. California 94549 •'"^ ' ^ '*' 

510.283.4981 



30-1 



30-2 



Mr. John S. Gregg 
May 8, 1992 
Page 2 



3. The Los Vaquero3 Pipeline Has Enormou3 Impacts For Both 
Existing and Proposed Land Uses On Covell Ranch 

The impacts of the pipeline alignment on the Cowell Property 

are contrary to the statements in the Draft EIR/EIS set 30-3 

forth on page 12-18. 

The S.H. Cowell Foundation owns a 4,900 acre ranch southwest 

of Brentwood on which it proposes to construct 7,500 homes. 

The pipeline alignment runs through the middle of an 

existing 2 3 5-acre granny smith apple orchard, planted in 3o_4 

1986. The proposed pipeline alignment would extend some 

2,300 feet diagonally into the orchard and would severely 

interfere with farming operations in addition to eliminating 

a significant number of trees. 

The Foundation is currently engaged with the County's 
Community Development Department in a General Plan Amendment 
study and rezoning for the entire property as approved by 
the County Board of Supervisors. Please refer to the Contra 
Costa County Community Development Department file for 30-5 
information on that review process. The process also 
involves significant participation by the City of Brentwood. 
The proposed General Plan for Brentwood includes the Cowell 
Ranch as a future specific plan area for mixed-use 
development. 

The preliminary development plan for the Cowell Ranch 
contemplates a long range program involving several thousand 
new dwellings, significant space for business and job 
intensive land uses, comprehensive trails and recreation 
facilities, together with appropriate civic and educational 
facilities to support the new neighborhoods. The master 
planning of this unique property represents a significant 
opportunity to address wide ranging community needs in east 
Contra Costa County and the City of Brentwood. 

The pipeline right-of-way is proposed to follow an alignment 
through a portion of the Cowell Ranch that is proposed for 
higher density housing which is affordable to a broad 
segment of the community combined with future employment and ^q^^ 
commercial uses. The alignment proposed by CCWD would run 
directly through this area, creating a permanent barrier. 
The harm this alignment would do to the development 
alternatives for the Cowell Ranch would be enormous. 



5-169 



Mr. John S. Gregg 
May 8, 1992 
Page 3 



Cowell's ability to acconunodate the CCWD pipeline is limited 

primarily by site topography and planning considerations. 

The area in question is one of two such areas on the Cowell 

property that are sufficiently flat to allow for 

environmentally appropriate and cost effective residential 

and mixed-use development. The rectilinear grid street 

pattern proposed for this part of the property is laid out 30-7 

intentionally in a north-south/east-west orientation to 

achieve maximum energy and land-use efficiencies. The 

proposed pipeline alignment would run diagonally through 

this village area in direct conflict with highest and best 

use considerations and sound land use and environmental 

planning. 

4 . The Pipeline Alignment Alternatives Are Being Limited, In 
Part, By Self-imposed Engineering Assumptions 

The key engineering design assumption that underlies the 
pipeline right-of-way alternatives is that the water must 
flow by gravity from the staging station just east of Walnut 
Blvd to the Randall Bold Treatment Plant. This is clearly a 
sensible approach from a long-range cost and reliability 30.3 
point of view. However, if the design included the 
possibility of pumping then the narrow and self-imposed 
topographic limitations for the pipeline could be relaxed 
and alignment alternatives less injurious to affected 
property owners could be considered. 

CCWD has chosen not to consider this different approach, 
despite the fact that massive pumping will be required to 
convey the water from its source in the Delta (at Clifton 
Court Forebay or other locations) to the staging site east 
of Cowell Ranch and to the Los Vaqueros Reservoir itself. 
The use of pumps for conveying water is common and adequate 
redundancy can be built into the system to protect against 
power failure and other malfunctions. The EIR/EIS needs to 
evaluate a system requiring pumps versus one that relies 
solely on gravity, and to assess and compare the additional 
costs against the value of the damages incurred by affected 
property owners as well as land use and environmental 
impacts in the area. 



30-9 



5-170 



Mr. John S. Gregg 
May 8, 1992 
Page 4 



Land Use Impacts Of The Pipeline Should Be Minimized 

As stated in the Draft EIR/EIS on page 12-18 CCWD should be 
required to coordinate the location of the Los Vaqueros 
Pipeline with individual landowners to reduce land use 
conflicts. The EIR/EIS should evaluate alternative 
alignments to determine which alternative would have the 
least impact including routes that would be contiguous to 
other rights-of-way or easements. Alternative routes 
through the Cowell property should include the following: 



a) a route parallel and adjacent to the Delta Expressway; 

b) a Walnut Blvd and Marsh Creek Road route; and 

c) a route parallel to the P.G&E. power line easement. 



30-10 



The Width Of The Pipeline Right-of-way Should Be Specified 

The Los Vaqueros Pipeline project is described on page 2-12 
of the Draft EIR/EIS. The pipeline is described as a 96- 
inch diameter single pipeline designed to deliver up to 200 
cfs of water from the transfer pumping plant to the Los 
Vaqueros Reservoir and to return water during normal 
operations at up to 4 00 cfs by gravity flow from the Los 
Vaqueros Reservoir to the transfer reservoir and then to the 
Contra Costa Canal. 

The width of the right-of-way is not stated in the EIR/EIS, 
although it is our understanding that CCVrt) intends to 
acquire by condemnation a 125-foot wide right-of-way. The 
EIR/EIS should evaluate the need for a 125-foot right-of-way 
versus the impact of narrower right-of-way. We question the 
need for a 125-foot right-of-way when the project only 
involves one 96-inch pipe. We think the width of the right- 
of-way grossly exceeds what is reasonably needed to 
construct and maintain this facility. 



30-11 



5-171 



Mr. John S. Gregg 
May 8, 1992 
Page 5 



The EIR/EIS should define and justify the width of the 
right-of-way required for the construction, maintenance and 
operation of the pipeline. If additional pipelines or other 
uses are contemplated they should be identified. All 
foreseeable uses for the right-of-way should be set forth, 
including the number of pipelines, other utilities and uses, 
depth, and maintenance requirements. Other foreseeable uses 
for the right-of-way should be set forth and their impacts 
studied. The EIR/EIS should set forth the nature of uses 
both permitted and prohibited within the right-of-way as 
well as contiguous to the right-of-way (i.e. parking lots, 
landscaping, trails, and crossing of the right-of-way) in 
order to determine the full impact. The proposed location of 
the pipeline alignment is an impediment to good land use and 
circulation planning. 



J 



The Proposed Pipeline Alignment Is Not Consistent With The 
County General Plan 

We believe that the pipeline right-of-way as currently 
proposed is not consistent with the County's General Plan. 
In support of this we cite as examples the following General 
Plan policies: 



a) From Chapter 5, Tr 
Policy 5-33 encourages 
transportation and dra 
According to this poli 
the Delta Expressway a 
and should follow the 
a distance as possible 
parallels the pipeline 



ansportation and Circulation Element, 

utilities to be grouped together with 
inage corridors, where appropriate, 
cy, the pipeline should either join 
lignment at the nearest possible point 
Delta Expressway alignment for as long 
or follow the P.G.&E. easement which 
right-of-way. 



b) General Plan Policy 3-1, page 3-43 calls for 
coordination of "... land use policies of the County General 
Plan with those plans adopted by the cities and special 
service districts." The EIR/EIS should cite all relevant 
policy language of the County General Plan and evaluate the 
proposed project against each such policy. 



30-12 



5-172 



Mr. John S. Gregg 
May 8, 1992 
Page 6 



The important relationship between the County's General Plan 
and the pipeline location is reconfirmed by Government Code 
Section 65402. That section requires CCWD to request a 
finding from the County that the location, purpose and 
extent of the Los Vaqueros project, which includes the 
pipeline, is consistent with the County's General Plan. 
County disapproval of the location of the pipeline may be 
overruled by the CCWD Board of Directors. However, of 
course, under Section 65402 and CEQA the EIR/EIS must 
evaluate the consistency of the pipeline location, in 
addition to other facets of the Los Vaqueros Project, with 
the County General Plan, in order to allow the CCWD to make 
an informed decision mitigating where feasible all 
significant environmental impacts. Inconsistency of the 
pipeline location with the policies and provisions of the 
County General Plan is a significant land use impact. CCWD 
has an obligation under CEQA to substantially mitigate that 
impact. On its face, there are inconsistencies with 
Policies 3-1 and 5-33, among other potential inconsistencies 
(e.g.. Goals 3-A, 3-C and 3-1; Policies 3-6, 7-5 and 7-D) . 
Such analysis is lacking in the Draft EIR/EIS. It should be 
noted that the East County Regional Planning Commission 
expressed concern about inconsistencies under the County 
General Plan between the pipeline location and proposed and 
long term land uses in the area. A decision was made to 
continue the public hearing to June 15, 1992, in order to 
give CCWD an opportunity to resolve such inconsistencies. A 
copy of Cowell's letter to the Planning Commission is 
attached for your review and comment. 



8. Implementation Of Mitigation Measure3 

CCWD should be required to coordinate the precise alignment 
of their pipeline with property owners and developers and to 
ensure that the impacts and mitigations are reviewed in the 
EIR/EIS in order to reduce conflicts to the extent feasible. 
Before the EIR/EIS is certified the total cost of a 
particular alignment, including land acquisition and 
severance damage should be considered in the cost analysis 
and not just engineering and construction costs. 



30-13 



5-173 



Mr. John S. Gregg 
May 8, 1992 
Page 7 



What guarantees exist that CCWD will adopt and implement all 
appropriate mitigation measures? Who will ensure that the 
pipeline alignment is properly coordinated with the master 
planning for Cowell Ranch? 

9. Impact Of Proposed Takeline On Cowell 

The EIR/EIS does not discuss the impact of a partial taking 
and the effects of creating uneconomic remnants on the 
remainder. The EIR/EIS should discuss the effects on land 
use on the Cowell Ranch for the area between the watershed 
takeline and Marsh Creek Road/Camino Diablo. The EIR/EIS 
also does not address CCWD's planned taking of Cowell 
property for oak tree mitigation. What are the effects of 
creating an uneconomic remnant between the reservoir take 
and the oak tree mitigation take? 

The impacts on the Cowell property include, but are not 
limited to, a division of the two largest developable areas 
on the Cowell Ranch, diminishing its highest and best use; 
an unnecessary division of planned communities and villages; 
a direct interference with arterial road and traffic plans; 
the creation of rigidity in the land use planning in 
response to right-of-way location; the desirable north-south 
street grid orientation will jeopardized; the set back and 
grid changes create irregular and uneconomic remnants; and 
the best solar orientation of the buildings will be 
considerably more difficult. 

In conclusion, the draft EIR/EIS is not a document that will 
allow the CEQA process to contribute to "informed self- 
government." The Draft EIR/EIS makes no attempt to analyze the 
compatibility of the pipeline and its location with respect to 
current and potential land uses in the area. Common sense would 
suggest that such an analysis is critical in evaluating the 
environmental effects of the pipeline, including its 
compatibility with potential land uses and land use policies, 
especially given that its proposed location is inside the 
County's Urban Limit Line. Under the County's General Plan and 
its 65/35 Land Preservation Plan, higher density urban level 
development is limited to land 



5-174 



Mr. John S. Gregg 
May 8, 1992 
Page 8 



within the Urban Limit Line. The Cowell Ranch is included in the 
land inventory for potential development through the year 2010. 
The pipeline will be a permanent feature in East County. It 
should be planned with that long-term view in mind, complimenting 
other land uses in the area, rather than competing with them. 
CCWD has an obligation to evaluate and mitigate such potential 
incompatibility through the environmental review process. 
Unfortunately, it would appear that the pipeline has been located 
with the idea that other potential land uses in the area and the 
application of the County's General Plan land use policies will 
simply have to work around it. Such an approach does not 
represent thoughtful environmental planning. Impacts of the Los 
Vaqueros Pipeline as proposed need to be better evaluated, 
feasible mitigation measures need to be spelled out in the 
EIR/EIS, and other reasonable alternatives need to be explored 
to make this environmental review and decision-making process 
adequate. 

Thank you for your consideration. 
Sincerely 

, iry wy Craft f) 
Projec4: Manager^ 



enclosures 

cc: Supervisor Tom Torlakson 

Contra Costa County County Development Department 
Attn: Harvey Bragdon, Community Development Director 
Gagen, McCoy, McMahon and Armstrong 
Attn: Mark L. Armstrong 



C:\WP51\D0CS\L0S 



5-175 



Response to Comments of the Cowell Ranch Project 



30-1. To allow the environmental review process to assist project proponents in siting project facilities 
to avoid and minimize environmental impacts, environmental review must precede final facility 
design. To fully address all the potential Impacts of the l-os Vaqueros pipeline, CCWD has evalu- 
ated a conidor larger than the proposed size of the facility. Because resource information has 
been gathered for this larger area, CCWD will be able to adjust the location of the pipeline to avoid 
and minimize environmental impacts. 

The preferred alignment of the Los Vaqueros pipeline is described on page 2-12 and is depicted 
on Figures 2-2 and 12-2 of the EIR/EIS. The description of the alignment is sufficiently pwecise 
to enatile the evaluation of impacts and proposed mitigation measures; Cowell Ranch Project 
comments address site-specific matters that indicate that the Los Vaqueros pipeline has been 
sufficiently described and depicted to allow impact analysis. 

30-2. Neither CEQA nor the National Environmental Policy Act require the project proponent to evaluate 
alternatives to each facet of a project. The discussion of the alternatives to the proposed project 
set forth in the EIR/EIS properly considers alternatives to the project as a whole and allows 
reasoned evaluation. 

30-3. It is assumed that the comment refers to page 12-17 of the Stage 2 EIR/EIS, which discusses the 
impact of the Los Vaqueros pipeline on an existing apple orchiard just north of Camino Diablo 
Road and west of Walnut Boulevard. The EIR/EIS finds this impact to be less than significant 
because It does not meet the significance criteria outlined on page 12-14. 

30-4. The information provided by the commenter does not affect the conclusion that the impact of the 
Los Vaqueros pipeline on agricultural production is less than significant. No information provided 
by the commenter substantiates the generalized concern that the pipeline would have a severe 
impact on the remainder of the orchard. Although no mitigation is required for this asserted 
impact, mitigation measure 12-1 would require CCWD to locate the pipeline in coordination with 
developers; this coordination may further ameliorate less-than-significant impacts. 

30-5. The configuration of the Cowell Ranch Project is subject to change by land use authorities and 
various other regulators. Attempting to determine the specific effect of pipeline siting on CoweH's 
proposed development would require considerable speculation. In the absence of sufficient 
information, the impact on the Cowell Ranch Project is considered significant. To reduce this 
impact to a less-than-significant level, the EIR/EIS recommends implementation of mitigation 
measure 12-1, which requires CCWD to coordinate siting the pipeline with proponents of other 
projects. 

30-6. See response to comment 30-5. 

30-7. The EIR/EIS recommends mitigation measure 12-1, which would require CCWD to coordinate with 
project proponents in appropriately locating the pipeline alignment to avoid impacts on future 
developrr>ents. The mitigation measure does, however, allow CCWD to take into account cost- 
effectiveness and engrr>eering feasibility. 

CCWD believes it has adequately addressed all the relevant land use Impacts of the proposed 
project in the EIR/EIS and believes thiat the mitigation measures discussed in Chapter 12, 'Human 
Environment", would reduce the impacts identified to less-than-significant levels. 



Response to Comments of the Cowell Ranch Project 

5-176 



30-8. Evaluating the alternatives suggested by the commenter may provide interesting or helpful 
information. This fact, however, does not require CCWD to include this information in an EIR/EIS. 
Studies corxJucted for these eiltemative pipeline siting would require speculative analysis, which 
wouJd delay project Implementation at greater cost to CCWD. See response to comment 30-2 and 
30-5. 

30-9. The concept of replacing the proposed gravity flow facilities with facilities that incorporate pumping 
to convey water from tfie transfer facilities to the Contra Costa Canal was considered early in the 
project planning stages. The concept was rejected for tfie following reasons: 

■ The gravity flow in this portion of tfie system increases its reliability. 

■ The additional power costs associated with such pumping. 

■ Alternatives using pumped flows in the area of the Cowell Ranch Project are more 
environmentally damaging. 

As IfKJicated in the response to comment 30-2, it is not necessary to discuss and evaluate 
alternatives to each component of a project. 

30-10. See response to comments 30-7 and 30-8. 

30-1 1 . See response to comment 30-2. Although the alignment is subject to final design evaluations and 
field conditions, CCWD plans to acquire rights to the 1 25-foot-wide right-of-way. A 125-foot-wide 
right-of-way is required for construction, operation, and maintenance of the pipeline. 

30-12. On June 15, 1992, the East County Planning Commission voted unanimously that the Los 
Vaqueros pipeline was In confomiance with the Contra Costa County General Plan. The 
conslsterKy of the pipeline is discussed in the EIR/EIS on page 12-7 and in Section D of the Stage 
2 EIR/EIS Technical Report. 

CCWD believes that the Los Vaqueros pipeline and process for siting the facility are consistent 
with the goals and policies of the county general plan. Certain general plan goals and policies that 
relate to CCWD's actions are referenced below (in the order they appear in the Contra Costa 
County general plan) along with an explanation of CCWD's actions as they relate to the goals or 
policies. 

Contra Costa 

County General 

Plan Goal No. Explanation 

3-A CCWD has experxJed extensive effort to coordinate with Contra Costa 

County and local jurisdictbns in siting the p>ipeline along existing and 
proposed transportation arxj utility corridors; mitigation measure 12-1 
will ensure that coordination with entities continues. 

3-C The Los Vaqueros pipeline will be Installed underground and the ground 

surface above the pipeline will be designed to be compatible with 
surrounding development. 

3-1 This goal has been furthered by CCWD's extensive coordination with 

local jurisdictions. 



Response to Comments of the Cowell Ranch Project 

5-177 



Contra Costa 

County General 

Plan PoJicv No. Explanation 

7-D The cooperative effort of CCWD and local jurisdictions in siting the 

pipeline has consistently focused on cost-effectiveness, as well as 
Improving the future well being of CCWD's customers. 

3-1 By providing additional employment opportunities, Implementation of the 

proposed project could contribute marginally to this goal. 

3-6 As discussed previously, CCWD has coordinated extensively with Contra 

Costa County and local jurisdictions. Implementation of mitigation 
measure 12-1 will ensure that this process continues. 

5-33 As discussed on page 18-4 of the EIR/EIS, Los Vaqueros pipeline has 

been located, wfiere appropriate, along existing and proposed utility and 
transportation corridors. 

7-5 See explanation for goal 3-A. 

30-13. The land acquisition process is described on pages 2-53 to 2-54 of the Stage 2 EIR/EIS and the 
costs of property acquisition, including an allowance for possible contingencies, such as 
severance damages, are set forth in Tables 1-4 in Sectbn A-1 of the Stage 2 EIR/EIS Technical 
Report. 

30-14. CCWD wyi adopt appropriate mitigation measures included In the Stage 2 EIR/EIS when it is 
certified. CEQA requires agencies to reduce the significant Impacts of a project to less-than- 
significant levels wherever feasible. Assembly Bill 3180 also requires the preparation of a 
mitigation monitoring plan, which will also be adopted at the time the final EIR is certified. 

Reclamation must also prepare a document, known as the record of decision, that adopts and 
summarizes a monitoring and enforcement program for all mitigation. 

30-15. The comment appears to confuse eminent domain procedures with the environmental review 
process. The impacts of mitigation measures need only be discussed if they result in significant 
impacts. Since creation of an "uneconomic remnant" does not directly or indirectly cause an 
adverse physical effect on the environment, the EIR/EIS is not required to address the effect. 
Neither CEQA nor NEPA are intended to protect against the decline in value of income-producing 
fxoperty. 

30-16. See the response to comment 30-15. 

30-17. See comments 30-1 through 30-14. CCWD believes that the document represents a good faith 
effort to inform decision makers and the public of the environnnental effects of the proposed 
activities and identify ways In whk;h environmental damage can be avoided or significantly 
reduced. 



Response (o Comments of the Cowell Ranch Pro/eci 

5-178 




LEAGUE OF LETTER NO. 31 

WOMEN VOTERS 

OF THE BAY AREA ^ 

An Inter League Organization of the San Francisco Bay Area C^ ^5 (^ 

y^^ v^.a.-^.^ "*y ^2, 1992 ^^^,^ 



Janice Hutton 

Contra Costa Water District 

P.O. Box 4121 

Concord, CA 95825 

RE: COMMENTS ON DEIR/EIS FOR LOS VAQUEROS PROJECT 

Dear Ms Hutton: 

The League of Women voters of the Bay Area appreciates the 
opportunity to submit questions and concerns about the Draft 
Stage 2 Environmental Impact Report /Environmental Impact 
Statement for the Los Vaqueros Project. Our questions and 
concerns are attached. 

We understand the District's concerns about its very limited 
emergency supply and water quality problems. We also believe it 
is essential that the EIR/EIS adequately reflect existing 
conditions, adequately identify and assess adverse environmental 
impacts of the project and mitigation measures to compensate or 
offset project impacts. 

Generally, our concerns focus on adverse impacts to aquatic 
resources, including wildlife, plant communities and endangered 
species. We are concerned that the importance of impacts to 
important natural resources, fish, plant communities emd 
wildlife, tend to be minimized, and that some of the proposed 
mitigation measures would not adequately compensate for adverse 
impacts of the project. In many cases descriptions of mitigation 
measures are too vague to allow evaluation about their 
feasibility or potentially successful. This is a particular 
concern for special status species and ecosystems. 



31-1 



In many instances it is unclear whether or not Impacts could be 
avoided. Avoidance is the preferred mitigation in CEQA. in other 
cases, the adequacy of a proposed mitigation seems magnified. For 
example, reducing the loss of 180 acres of mature (150-250 year 
old) Valley Oaks, or 80% of the Valley Oaks In the watershed, to 
a level of insignificance simply by plantings at a ratio of 3:1. 
Each mitigation measure sets a precedent for future projects. If 31-2 
this mitigation is deemed adequate to reduce a loss of such 
magnitude to insignificant, this will become the standard for 
future losses. There is almost no conceivable impact to Valley 
oaks that couldn't be reduced to insignificance by planting a few 
young trees. We suggest that partial mitigation could be 
accomplished by the 3:1 planting but that the impact still be 

RECEIVED 

MAY 1 2 1992 

500 St.Mary'sRoad. Suite 14, Lafayette, 08 94549 •Tel. (415) 283-7093 'Fax 283-2613 



recognized as significant and findings of overriding 
consideration be adopted. 

Thank you for considering our conunents. 



ely, 





th Packa 
President 



cc: Local Leagues 



5-180 



LWVBA QUESTIONS ON DRAFT STAGE 2 ENVIRONMENTAL IMPACT 
REPORT /ENVIRONMENTAL IMPACT STATEMENT FOR THE LOS VAQUEROS 
PROJECT 

1 . Several of our questions submitted in response to the Scoping 
do not appear to have been addressed: 

- the length of time it would take for the reservoir to be 
filled initially. 

- a presentation of the flow standards in the SWRCB Salinity 
Standards document for the Bay/Delta and an analysis of whether 
the diversions for the Los Vaqueros project would bring Bay Delta 
flows below those standards. 

- an analysis of whether there is sufficient water in the state, 
or more specifically in the Bay/Delta system, during dry years to 
supply all existing water rights holders plus allowing additional 
water to be diverted without resulting in significant 
environmental damage. 

2. The discussion on page 1-3 and 1-4 points out that CCWD's 
emergency peak demand water supply is 3 to 5 days, while other 
district's have a greater supply. How many other districts, if 
any, have minimal provisions for emergency? If there are others, 
give some examples and discuss how these districts manage. 

3. Could a desalination plant be operated to produce less fresh 
water during winter and spring? Explain why Sulsun Bay was 
chosen as the discharge point for brine. Evaluate the 
feasibility and impacts of disposing of brine in San Pablo or San 
Francisco Bays. 

4. In the light of the decline of aquatic species dependent on 
the Delta, data supporting the accuracy of the following 
statement (paragraph 4 page 3-1) should be provided: "Over about 
thirty years, SWRCB decisions have developed permit terms and 
conditions to protect beneficial uses of Delta Hater." 

5. There is substantial evidence that existing diversions from 
the estuary are contributing to decline of species dependent on 
the estuary, we do not believe that existing conditions should be 
considered an acceptable baseline condition. The comparison of 
potential project impacts against a No-Action Alternative appears 
to facilitate a conclusion of No Significant Impact. 

6. Data should be provided to substantiate the statement (page 
4-5) that "riverine factors are the main cause of winter-run 
(Chinook Salmon) decline...." As noted in the STR for AQUATIC 
RESOURCES OF THE SAN FRANCISCO ESTUARY "A high correlation has 
been shown between outflow and most measures of smelt abundance 
and survival." Loss of fresh water flows should be identified 
as a contributing factor In the declines of the winter-run if not 
other runs. 

5-181 



31-3 



31-4 



31-5 



31-6 



31-7 



31-8 



31-9 



31-10 



7. Decline of fresh-water flows should be identified as a 
contributing factor in the decline of Striped Bass and Delta 
Smelt as well. According to the Federal Register notice 50 CFR 
Part 17, Proposing the Delta Smelt for Endangered Status, 
"Available data indicate the decline in the delta smelt 
population has been concurrent with Increased human changes to 
seasonal Delta hydrology, freshwater exports and the accompanying 
changes in the temporal, spatial and relative ratios of water 
diversions." and "Since 1983, the proportion of water exported 
from the Delta during October through March has been higher than 
in earlier years. These proportionally higher exports have been 
conducted during the delta smelt's spawning season." The 
cumulative impact of the proposed diversions on Delta Smelt 
should be addressed. 



31-1] 



8. The meaning of the following statement (page 4-10) is 
unclear: "The level of significance depends on the ability of the 
species to maintain or exceed current production levels through 
mechanisms that compensate for reduced abundance of earlier life 
stages." This statement indicates that some or all of the 
special-status species that would be impacted by the project 
could, somehow, compensate at other life stages for the adverse 
project-related impacts. Identify specific species and 
demonstrate how they would compensate for reduced abundance. 
This criteria seems to Invite an assessment of "no significant 
impact . 

9. Demonstrate the validity of the assumption for the No-Actlon 
Alternative (page 4-11) that "demands for water from the 
Sacramento River, San Joaquin River and other rivers by all users 
(would) increase." As in #8 above, this parameter seems to set 
the stage for reducing the significance of the project Impacts. 



31-lJ 



31-1. 



10. It seems to us that listing as em endangered species 
warrants a finding of significance even if the project would 
cause "a less than 1% decline In mortality" (see Chinook Salmon, 
page 4-24). Also, even a "slight" contribution to significant 
Delta-wide cumulative Impacts on a candidate species for 
endangered listing (page 4-30), namely the Delta Smelt, should be 
significant. The preferred mitigation in CEQA is avoidance. Has 
an alternative been investigated that would require no Increase 
in fresh water diversion? 



31-14 



1 1 . The DEIR concludes that the "Impacts of Increased diversions 
(on the Delta Smelt) during winter years would... be largely 
offset by decreases in diversion ...during dry years" (page 4-30) 
is not clear and should be explained. 

12. On what basis does the DEIR justify the assumption that the 
North Delta water Management Program, the Los Banos Grandes 
Reservoir, Kern Water Bank, Delta Wetlands project would be 
implemented. A scenario should be developed evaluating the 
adverse impacts of the project without these projects. 



31-1' 



31-16 



5-182 



13. CCWD proposed to mitigate for impacts on fish poDulatlon« k 1 
increasing production rather than increased survivK or in okk^ 
words through fish hatcheries. We question the adequacy o? ^^ 31-17 
mitigating for natural fish populations with hatchSy stock. 

^** f??®..^~*^ cites "preserve riparian vegetation wherever " 
possible" as a mitigation measure for impacts of the water 
conveyance pipeline construction. This mitigation is Jo vaoue 31 18 
that it is meaningless. Estimate how much riparian vegetation 
could be avoided and how much could not be avoided? ®^*''*^^°" 

15. The discussion of Kellogg Creek page 6-4 should indicate 1 
that because of California's Mediterranean climate, maSy or most 
streams are seasonal. The current discussion could be 31-19 
Interpreted to mean that Kellogg Creek is not a significant Creek 
because it does not flow year-round. -isniricanc creek 

16. What length of stream habitat would be lost with 1 -n on 
construction of the reservoir? J 31-20 

^1',^*°^^ ^P®*'^^^*' information should be provided about the 
studies used to support the conclusions on page 6-13, that ,, oi 
? i!?f? bacteria from gulls that would be attracted to nearby ^^'^^ 
landfills would not be a problem. 

18. The location of the Mt. Diablo manzanlta, other special 
status plant species, Valley Oak and other native trees should be 31-22 
shown on a figure. 

19. We have problems with several of the proposed mitigations. 
Surveys are not mitigation and should be conducted prior to the 
DEIR. Why the various adverse Impacts to oak trees on page 7-36 
(irrigation within the dripline, soil compaction and paving 
within driplines etc.) cannot be avoided Instead of simply 31.23 
mlnlmired is unclear. Protection and enhancement as is proposed 
as mitigation for the loss of 35.6 acres of blue oak woodland, 
even If the acreage protected is large, still represents a loss. 
The discussion should also address why the numbers of native 
trees that would be lost cannot be reduced. 

20. Paragraph 7 on page 7-17 states that CCWD "will release 
downstream flows sufficient to maintain wetlands that occur 
between the Los Vaqueros dam site and Camlno Diablo Road." This ,, -,. 
statement Is vague. The DEIR should Indicate how these decisions 

will be made: Who will require these releases, under what 
authority, according to what criteria and at what point in time? 

21 . Comments from the Army Corps of Engineers Regulatory Branch 
as well as other regulatory responsible and Interested agencies 
(US Fish and Wildlife Service, National Marine Fisheries, CA 31-25 
Dept. of Fish and Game etc.) should be provided. The DEIR should 
state whether an Alternate Site Analysis been developed amd 
discuss its contents. 



5-183 



olzK/.M"' '^^""^ »"'9at.o„ px.„ ..oula .e incluaea x„ the 
•o ., to ..sure opportunity for sSccees '"" °' ""* P'°J»°t 

fe^rL"" T»" ver*srpio\%r?-"f s^^r^^?- '" ^°" «' 

provide no net loss of h-Kt^-*. ^ litigation goal: "to 
Claypan Vernal P^ls Ire SncoL^n"*^! *"^ values!"" Northern 
unique assemblagrof plants ??°' f"^ **°»^ ^•^"al pool hJs a 
«ltlgation for the loss of r J * ^^ "° indication that 
likely. AS statel above the »os? ^!T^ ''^'^ '^ ^«"^ble or 
construct and mitigation 'vernar^?!""^"* J" *f"°" ^°"1^ b« to 
those exiting and require ^''^'''' ^° destruction of 

w^lL^%^s^u^1^L^^^1e^s1u^\rc'i^^^^^^^^^^ r ^°^? °^ ^^^-^- 

establishes and no long" reauire ^rM^/*"*" sapling are 

may indicate a successful Itl^tlt H^ management. While this 

habitat habitat as complex as the existing riparian 

26. Sizable populations of six special-status plant SDecies rnt 
Diablo manzanita, brittlescale, San Joaquin spearscalef 
stinkbell Diablo helianthella and Brewer's dSarf flax some 
representing substantial portions of the total known world 
populations exist within the project area. The DEIR is vague 
about how much loss for each species would occur. While the 
discussion on mitigation (page 7-43) lists a number of criteria 
for a mitigation plan for special-status plant species, however, 
it also states that "attempts to establish new (special status 
plant) populations generally have not been successful." This 
renders the feasibility of mitigation highly doubtful. What 
attempts have been made to avoid endangered plant populations? 
Has the District sought consultation under the Endangered Species 
Act with the US Fish and Wildlife Service? As above, the best way 
to assure successful mitigation would be to implement the 
mitigation prior to the loss, and with sufficient time to 
assesses its success. 

27. The Los Vaqueros reservoir would inundate an estimated 1,042 
Valley Oak trees (180 acres) estimated to be 150 to 250 years old 



31-21 



31-27 



31-2, 



31-2| 



31-3^: 



31-3 



5-184 



mature (150-250 years) Vallevft»i^. ^?^* °^ 180-acres of 
replacement of 6u«[?len? ^[^ounf Jo o?J°''J''^J*^^ ^'0«, the 
term habitat valuef anfac^age losses'^ithln^T^'""'" '^'^f ^°"3- 
highly questionable and dange?ously precedei? ILl^^""^' ^° ^« 
150 to 250 years old tree be considered ™?« netting. How can a 

^n?!""^"'"^''""" *» *° "establish an spproprJatl bSn« 

rLuit?^o^?^L*'3"'"S'' °" P*'* '"-■'^ Inaicates that .lltation 
resulting from aam ana reservoir construction and operation is 

2m»i?^^S J° ^\t P'^o"!*"" because "the watershed is relatively 

small and most of the reservoir slltation wouia occur only durlno 

the winter ana early spring months." The latter point is true 31-36 

throughout the Bay Area and southern California. In a 

Heaiterranean climate, erosion and sedimentation of creek 

environments occurs during the rainy season, except in tidal 

C*e©K8 • 

33. Best Management Practices are recommended as a mitigation 
measure for dam and reservoir construction. To enable the public ,, ^^ 
to evaluate the adequacy of this measure, the DEIR should state ^^'^' 
what best management practices would be used. 



5-185 



31-13. DemarxJs on Sacramento and San Joaquin River systems are expected to increase in the future 
as the population of Califomia increases. If new water supply sources are developed or new Delta 
water quality standards make increases in diversions from the Delta impossible, then conditions 
woukj remain as described under the "Affected Environment" section. 

31-14. Most fish species are capable of sustaining large losses of some life stages without affecting the 
adult population. l_osses of winter-njn chinook salnnon and Detta smelt attributable to the Los 
Vaqueros Project are very minor and, as stated in the EIR/EIS, would not measurably affect adult 
populations. 

As a result of comments received on the EIR/EIS and meetings with the various resource 
agencies, CCWD and Reclamation have developed mitigation measures that not only reduce 
impacts to De<ta resources, but actually improve conditions as compared to no project, particularly 
for winter-run chinook salmon. These measures consist of revisions to the proposed project 
operations in terms of the timing and magnitude of diverskxis from the Delta during the winter-run 
Chinook salmon's season of highest vulnerability. Under the proposed mitigation plan, CCWD will 
use a portion of the water stored in the Los Vaqueros Reservoir in lieu of direct diversions from 
the Delta. This operation will allow CCWD to eliminate aN diversions from the Delta, including 
those from its existing intake at Rock Slough, for a total of approximately 30 calendar days 
between March 15 arxJ May 15 of each year. In addition, CCWD will generally not fill the Los 
Vaqueros Reservoir between March 15 and May 31. 

The revised project operations are fully described in the biological assessment for the proposed 
project as are the effects of the revised operations on special-status fish sfjecies. The mitigated 
operatksns are also described in Chapter 4 of the final Stage 2 EIR/EIS, along with a discussion 
of effects on other fish species. 

31-15. The proposed project would result in increased losses of Delta smelt during wetter years, when 
CCWD would divert additional water to refill the Los Vaqueros Reservoir, and increased sun/ival 
during drier years, when CCWD would reduce its diversions from the Delta and rely instead on 
water stored in the Los Vaqueros Reservoir. These increases and decreases in survival offset each 
other and would not contribute to population declines of the Delta smelt. In addition, CCWD's 
revised operations generally preclude filling the Los Vaqueros Reservoir tietween March 15 and 
May 31. 

31-16. The Stage 2 EIR/EIS assumes, for purposes of analyzing potential cumulative impacts, that the 
referenced projects may be constructed in the future. In addition, as suggested in the comment, 
both the existing corxJitions and future conditions analyses in the Stage 2 EIR/EIS assess the 
direct impacts of the proposed project, assuming that no additional water projects are 
constructed. 

31-17. See response to comment 31-14 above. 

31-18. The impact analysis contained in the Stage 2 EIR/EIS assumes a worst-case condition that all 
vegetatkxi within constructbn corridors would be affected. The resulting losses arxJ 
recommended mitigation measures are described in Chapter 7, "Vegetation Resources". The 
referenced mitigatk>n measure is intended to reduce soU eroskxi and recognizes the value that 
riparian vegetation can play in reducing soil erosion. 

31-19. Comment noted. The informatkxi on page 6-4 is intended only to provide a description of Kellogg 
Creek, in conventional terms. 

31-20. The length of stream channels, including Kellogg Creek, that would be affected by the proposed 
project is described on page 8-17 and equals 7.7 miles of ephemeral stream channel. 



Response to Comments of the League of Women Voters of the Bay Area 

5-188 



31-21. As described on page 6-13 of the Stage 2 EIR/EIS, CCWD undertook a study of this issue and 
determined that no potential for effects on drinking water quality exists even under worst-case 
conditions. The results of this study are summarized in the Stage 2 EIR/EIS. Since there is no 
potential for significant effects, CCWD believes that adequate information is provided. CCWD will 
provide copies of the referenced study on request. 

31-22. The location of valley oak woodlands within the Kellogg Creek watershed is shown in Figure 7-1 
of the Stage 2 EIR/EIS. The locations of other special-status plant populations and significant 
natural communities are described in Sections C-1 and C-2 of the Stage 2 EIR/EIS Technical 
Report. 

31-23. The Stage 2 EIR/EIS does not describe surveys as mitigatkDn. In some cases, specific facility 
locatkans have not yet been identified or it is unclear wfiether impacts can be avoided. In such 
cases, a worst-case analysis was conducted and mitigation measures are proposed to ensure that 
impacts are avoided and minimized as much as possible during the planning and design process 
and that any remaining impact is fully mitigated. 

The impacts to oaks described on page 7-36 are intended to recognize that despite all avoidance 
efforts, some impacts may occur and mitigation should be identified. Blue oak woodlands are not 
considered a significant resource in the project area and small losses are not considered 
significant impacts. 

31-24. CCWD will be responsible for ensuring the maintenance of flows downstream of the dam to 
maintain wetlands, between the dam site and Camino Diablo. 

31-25. All comments provided on the draft Stage 2 EIR/EIS are included in the final Stage 2 EIR/EIS. 
The Stage 2 EIR/EIS heavily references the Section 404(b)(1) alternatives analysis that has been 
prepared for the project and summarizes its contents and results. The altenriatives analysis, which 
analyzes over 120 alternatives, has been completed and provided to the Corps and other 
agencies. 

31-26. A site-specific wetland mitigation plan has been prepared and is included as an appendix to the 
final Stage 2 EIR/EIS. A mitigation monitoring plan will be adopted by CCWD when the project 
is approved as required under CEQA. 

31 -27. CCWD has consulted extensively with the U.S. Fish and Wildlife Service, the California Department 
of Fish and Game, the U.S. Army Corps of Engineers, and the U.S. Environmental Protection 
Agency regarding wetlands mitigation planning. The wetland mitigation plan, which is included 
as an appendix to the final Stage 2 EIR/EIS represents the information developed during that 
consultatkKi. CCWD has aiso conducted extensive pilot studies that demonstrate the effectiveness 
of the mitigation plans. 

31-28. The proposed (xoject would affect less than 0.01 acre of northem daypan vemal pool. The 
wetland mitigation plan proposes to compensate for this impact by creating out-of-kind wetlands 
to achieve no net loss of acreage and values by enhancing other northem daypan vernal pools 
in the project area. 

31 -29. CCWD believes that the proposed mitigatbn measure adequately defines mitigation responsibilities 
for CCWD and ensures that impacts will be fully mitigated. 

31 -30. The Stage 2 EIR/EIS dearly states in several locatk>ns (page 7-1 6, for example) that the proposed 
project woukj not result in any impacts on special -status plant species populations. In many 
cases, this condusion results from extensive efforts to avoid these resources. In addition, the 



Response to Comments oT the League of Women Voters of the Bay Area 

5-189 



biological assessment describes potential effects on special-status plants in detail. Beyond 
avoidance that was already urxJertaken, no further mitigation Is required. 

31-31. See response to comment 31-2. As dearly described In the Stage 2 EIR/EIS, the loss of these 
valley oak woodlands is unavoidable except through selectkxi of another alternative. Therefore, 
the Stage 2 EIR/EIS proposes mitigation for this Impact. 

31-32. The proposed project would result In the protection of over 1 1 ,000 acres of suitable San Joaquin 
kit fox habitat. In addition, CCWD has agreed to acquire and protect an additional 1,000 acres 
outside and east of the Kellogg Creek watershed. Additional details regarding mitigation for wildlife 
species is contained in the biological assessment. 

31 -33. Consuttatkxi under the federal Endangered Species Act is completed. The biological opinions are 
summarized in Chapter 20, "Consultation and Coordination". 

31-34. The precise extent of any buffer zof>e is variable depending on site-specific conditions. CCWD is 
committed to ensuring that appropriate buffer zones are established and that significant impacts 
are avoided through consultation with a qualified wildlife biologist and implementation of specific 
recommendations. 

31-35. CCWD believes that the referenced mitigation measures are adequate to reduce impacts on these 
species to less-than-significant levels. Additional detail on these mitigation measures is contained 
in the biological assessment. 

31-36. Comment noted. 

31 -37. Dam and reservoir construction and operation are closely regulated by the California Department 
of Water Resources' Division of Safety of Dams. CCWD is engaged in extensive coordination with 
division and will comply with all applicable provisions of state and local law and regulation. 



Response to Comments of the League of Women Voters of the Bay Area 

5-190 



APR-30-92 THU 17:14 



•^^' 









CCWD-Gn 



FAX NO, 6748197 



P, 02 
LETTER NO. 32 



Li iC ^.i o ; 



. *~ * I. 



C» isT «< 'T^. .■ ' 



■ C ... ^ 
^i'":":ci',t 



j'J'.ir' .'.-■ .-nT : 



V 'J I . 



■'-'ILL;) orGoniratioi"! in ban t^ar.vjr, ! ciavtr 



:r,duc;r.: ::r,5,ec;ocr.c^3 :' 'n-i :>ro;ect i f ir-a thss hare to Delieve, since 
..iU; ^«o;1<:;1:;'ilv !,.: ci^je !:o me pi^nr^^c eADansion o' tnc Douanrriv ana 
Ta35aj3rj Vallevs -.voulu iDe mcrity ternDting. As of this writing, the 
Dougnerty Va'.ley future deveioprnf^nt of apDroximateiy 10.500 hemes does 
net r,3vc 3 vvater s'JDpl'cr source I tnink Los vacueros aou'-O soive this 

IJI t/u I Ci i 1 1 vj\-'i 1 I. / ■■."-■ : 1 ' 

Q»-;^l..f'- 1 .*« r» -^. i- *■ .- : '• ». ,* . 
I •>./ tT ;.! ■ 1 1 I .P'.^',. '. O III ■.III. 

•^•*.'* • ^ 1^ *■ r^ ^ ' • ^ .-. .V. * 



EiP: "leedc neeos to evaiu^te rri.:.re fuiiv _tn,e 
rqion of Contra Costa County, aacressmq tnese 



32-1 



2. Relocation of vasco Road to accommodate this project could posstDly 
be growth ipiducina to areas West of the project, such as the Brentwood 
and Oakley areas, i am also concerned that the new routing of Vasco Road 
is in the vicinity of the talked about Toll Road Project, and would hope 
that the Toll Road would not oe the replacement for Vasco Road, i would 
like to see more evaluation cone on possible growth inducements relative 
to road relocations. 



32-2 



3. 1 might draw vcur attention to the fact that a similar mistake was 
made by not fully exploring growth inducing impacts of the Super Sewer, 
understand that a lawsuit against the Trl-Valley Wastewater Authority 
brought iDy the 5ie*ra Club/Greenbelt Alliance/PARC was successful in 
that the courts orcered 3 new EiR be prepared which fully addressed the 
growth mducinc affects of the project. 



32-3 



iM.ji,K ,..-o ; ui V >- ur ci^ I.e. 1 1. lO' 



•J ii itti tr I V 



H.aroidBushjvv 
97;0TareytCh Ave 
San Row-ion, CA v^553 

\ -- I V / 1^ ^ '^ V . ' . 



5-191 



RECEIVED 

APR 3 1992 



Response to Comments of Harold Bushaw 



32-1. The Los Vaqueros Project has been sized to provide water quality and reliability benefits to 
CCWD's existing service area in northern and central Contra Costa County. The Los Vaqueros 
Reservoir would not increase the supply of water available to CCWD and would therefore not 
increase the likelihood that CCWD would provide CVP water service outside of its existing service 
area. 

32-2. The potential growth-inducing impacts of relocating Vasco Road were fully described in both the 
Vasco Road and Utility Relocation Project EIR and the Stage 2 EIR/EIS. The conclusion of each 
of these documents is that relocating Vasco Road is unlikely to result in substantial new growth 
because of the remoteness of the area and current zoning and land use restrictions. The Stage 
2 EIR/EIS did identify that small-scale growth potentially induced by the project could result in 
significant impacts on vegetation resources. Mitigation measures were identified to reduce this 
impact to a less-than-significant level. 

The relocation of Vasco Road is not associated with the development of any toll road. In a letter 
to Betty Boatmun, former president of the Contra Costa Water District Board of Directors, the 
California Toll Company stated "It is our conclusion that the [Vasco Road and Utility Relocation] 
project, as certified, is not consistent with the transportation services that the Mid-State Tollway 
will provide." In addition: "For reasons given, we have urged CCWD to pursue its project planning 
independently and leave regional transportation planning to the respective County agencies." 

32-3. CCWD believes it has fully complied with the State CEQA Guidelines regarding the treatment of 
growth inducement of the proposed project and alternatives. 



Response to Comments of Harold Bushaw 

5-192 



state water 
contractors 



555 Capilo) Mall. Suite 725 • Sacramento. CA 95814-4502 

George R BaumU. General Manager (916)447-7357 • FAX 447-2734 

CCfO /7f^f 




LETTER NO. 33 

Directors 

T}iomms E. Levy f^estoent 

Coacneiia I9«e/ ifaier Orsirci 

David e. Oklu Vice Pieioen 

Solano Counry VVaier Agercy 

Ouan* L Owf^non Seo-eUfy Treasufe/ 

MeiropoUan v^iet Ostfci 

or Sourftem Caitfornta 

ntomu N. CUrli 

Kern Coun/y V^dfef Agency 

Ron«MR.Euu 

Santa Qara leuey MO/ef Cfcs/fcf 

Thomit R Hurlbutt 

luU'e Lake ass*i Meief Sjorage OsJr*:; 

RolMrtN UcKlmwy 

C»s<as Wunopa/ Msiet D«/»ic( 

Okiton MItn* 

San tus Ot»soo Counry f 1000 Ct>W(y « 
Wfife< ConsefvQ/ion Disirci 
WlUaccG SplrurskI 
An(e* 



cc 



May 21, 1992 

Mr. Gaiy Darling 
Contra Costa Water District 
P.O. Box 4121 
Concord, CA 94524 






RE: COMMENTS ON THE FEBRUARY 1992 DRAFT STAGE 2 EIR/EIS FOR THE LOS 
VAQUEROS PROJECT, CONTRA COSTA WATER DISTRICT 

Dear Mr. Darling: 

As we understand, the Preferred Alternative, Los Vaqueros Reservoir with the Rock 
Slough/Old River No. 5 intake, would include construction of a 100,000 acre-foot (AF) 
reservoir and a new supplemental intake located in the Delta on Old River north of Highway 
4 and adjacent to Victoria Island. The purpose of the proposed project is to improve the 
quality of water delivered to Contra Costa Water District (CCWD) customers, to improve the 
reliability of water delivery by providing emergency storage, and to develop and construct the 
necessaiy facilities to have the program operational by 1995 with an estimated cost to CCWD 
in 1988 dollars of $350 million. The proposed program would allow water deliveries to 
CCWD under a water service contract with the Bureau of Reclamation to increase from 33-1 
130,000 AF/year to 195,000 AF/year. 

The State Water Contractors (SWC) support the concept of increased off-stream storage that 
can provide benefits to water quality, water supply reliability, and the enviroimient However, 
we are concerned about the potential impact of the proposed Los Vaqueros Project on State 
Water Project (SWP) operations, involving the Delta. It is the position of the State Water 
Contractors that any such impacts must be mitigated. 

The SWC understand CCWD's need to improve water quality and water supply reliability, 

and accordingly, supports the first two of the project's three primary objectives. However, 

the SWC is concerned that seemingly artificial limits imposed in the project's third primary 33-3 

objective — specifically to construct the project by 1995 within an estimated cost of $350 

million ~ may preclude development of a program which sufficiently mitigates for current and 

future impacts on Delta resources and water uses. PPP 



33-2 



5-193 



MAY 2 6 1992 



While development of facilities that adequately mitigate enviromnent impacts may be costly, 
limiting a project's overall cost may significantly affect the ability of the proposed program to 
adequately mitigate environmental impacts. Similarly, requiring that a project be completed 
within a specific short time period may require the sacrifice of greater environmental benefits. 

o While there may be compelling reasons to construct Los Vaqueros Reservoir prior to 
1995 and for less than $350 million, the technical reasons supporting such a goal need 
to be clearly identified in the Final EIR/EIS to ensure that the project does not 
inadvertentiy circumvent the needs of the Delta environment and other uses of water 
from the Delta. 

o CX^WD should consider increasing the size of the new supplemental intake and 
increasing the capacity of the facilities necessary to fill the reservoir. Increasing the 
capacity would reduce the duration of pumping in the Delta. By doing this CCWD 
would maximize the ability to capture high-quality water and minimize the impacts 
associated with diverting water from the Delta during periods which are more sensitive 
to fisheries. 

One of the alternative intake aligimients identified in the draft EIR/EIS contemplates a 
connection with Clifton Court Forebay. The Department of Water Resources' (DWR) South 
Delta Water Management Plan (SDWMP) Draft EIR/EIS suggested the relocation of 
CCWD's Conti-a Costa Canal Intake to Clifton Court Forebay would provide CCWD with 
greater operational flexibility and improved water quality. 

o The SWC recognizes that it may not be currentiy practical for CCWD to interconnect 
its new supplemental Delta intake facilities with the existing Clifton Court Forebay. 
However, CCWD should consider, as an alternative, staging construction of an intake 
so that the facilities may be relocated to an enlarged Clifton Court Forebay in the 
future. This alternative should also recognize that other Delta water transfer facilities 
are being investigated by DWR as part of the Governor's State Water Policy, and that 
such facilities could provide CCWD with an alternative means to meet its objectives 
and provide significant additional benefits. 

The draft EIR/EIS shows in figure 2-3 and sfates on page 1-10 that the project will enable 
OCWD to increase annual diversions from 120,000-130,000 AF under existing conditions to 
174,600-188,000 AF under full build-out demands. However, the EIR/EIS also states that 
consistent with CCWD's Resolution No. 88-45, one objective considered in developing the 
Los Vaqueros Reservoir Project was to, "Not operate ... [to] increase the export of Delta water 
from northern California without additional voter approval." There appears to be an 
inconsistency between the projects purpose and the sfated objectives. 

o The Final EIR/EIS should identify that one of the primary objectives is to divert more 
water from the Delta to increase CCWD's ability to meet increased water demands. 



5-194 



DELTA- WIDE WATER MANAGEMENT 

The Sacramento-San Joaquin Delta (Delta) is a complex region through which two-thirds of 
all of California's developed water supplies are transported and where diverse habitat exists 
for a variety of biological resources. Consequently, programs that increase water diversions 
from the Delta can have a significant impact on many existing Delta uses. The following 
concerns identify Delta water management issues which must be clarified or addressed in the 
EIR/EIS. 

Proi'ect Description and Operations Need to be Clarified 

The draft EIR/EIS states that, "Reservoir filling would occur when surplus water of adequate 
quality is available in the Delta between November 1 and June 30." It also states that, "when 
diverting water to the Contra Costa Canal for direct use, CCWD would give preference to the 
intake that could deliver the best water quality." 

o The phrase "surplus water" should be defined. 

o The EIR/EIS should identify the projected diversions for the alternatives considered 
from both the Rock Slough and new supplemental intakes. This information should 
include projected monthly diversions: from the new supplemental intake to fill Los 
Vaqueros Reservoir, from the new supplemental intake directly to the Contra Costa 
Canal, and from the Rock Slough Intake. The EIR/EIS should also indicate the 
projected change in quantities of diversions from current levels. 

Diversions to fill Los Vaqueros Reservoir would correspond with the period in which other 
Delta users have a high demand for Delta water. Diversion by the SWP and CVP are highest 
during the winter and spring months. In addition the SWP has proposed utilizing increased 
pumping capacity to divert excess Delta outflow during this period to store water in south of 
the Delta storage programs such as Los Bahos Grandes and the Kern Water Bank. Further, 
the winter-run Chinook salmon requirements may constrain the availability of high-quality 
water during this period and conflict with reservoir filling operations. 

o The Final EIR/EIS should include information which demonstrates that there will be 
sufficient water available to fill the Los Vaqueros Reservoir when all demands on the 
Delta are considered. 

The EIR/EIS states that diversions to fill the reservoir will take place through June 30 when 
adequate water quality is available. The SWC is concerned that there may be significant 
adverse impacts to Delta fisheries from increased CCWD pumping in May and June. These 
impacts would further degrade Delta fisheries and consequently could increase the restriction 
on SWP operations to divert water from the Delta. As you are aware the SWRCB has 
severely restricted SWP and CVP diversions in May and June to reduce project impacts on 
Delta fisheries. Additional limitations may be placed on the SWP and CVP in other months 
with interim standards to be adopted by the State Water Resources Control Board. 



5-195 



o The EIR/EIS should identify how the Los Vaqueros Reservoir project would be 

impacted if similar limitations are placed on its operations. Also, the impact on SWP 
operations due to operations of the Lx)s Vaqueros Project should be identified. 

o The EIR/EIS should identify the effect of pumping on Delta fishery resources, 
particularly during periods when the SWP and CVP are subject to restrictions, and 
should discuss what restrictions may be applied to CCWD's proposed program during 
those crucial months. 

As a leader in the Best Management Practices (BMP) process, CCWD played a key role in 
developing a statewide conservation strategy to reduce future water demands. However, it 
is unclear how BMP's and other conservation strategies will be incorporated into Los 
Vaqueros Project 

o The EIR/EIS should identify what steps are being taken by CCWD, and cities within 
its service area, to reduce water demand. 



Impact Analyses Need to Be Revised 

To determine the effect of the proposed project on Delta resources, several computer models 
were used. DWR's Central Valley Simulation Model (DWRSIM) was used to determine 
changes in reservoir storage, river inflows, Delta inflow, Delta outflow, and Delta exports. 
Information from DWRSIM was used in the Fisher Delta Models to calculate flow and TDS 
distribution in the network of Delta waterways. 

o Demands for SWP contractors, excluding the Feather River contractors, used as input 

to the DWRSIM model runs under future conditions (year 2000) were 3.7 million 
acre-feet (MAF) per year. The SWP contractors' total requests, excluding the Feather 
River contractors' requests, were 3.6 MAF in 1992, and will likely exceed 3.7 MAF by 
the year 1993. The underestimated SWP year 2000 demand might result in 
underestimated impacts on Delta hydrodynamics, fisheries, and water quality. A 
modeling run with higher, more representative demands should be made. Our 
estimate for the year 2000 SWP demand is 3.9 MAF. 

Chapter 18 "Cumulative and Growth Related Effects" neglects to identify the cumulative 
impacts of the proposed Los Vaqueros Project when operated in conjunction with future SWP 
fecilities. However, Chapter 3 "Delta System Hydrodynamics", Chapter 4 "Delta System 
Fisheries Resources", and Chapter 5 "Delta System Water Quality" contain discussions of the 
environmental consequences under cumulative future conditions. In these discussions, it is 
unclear what studies are being examined for the particular alternatives. 

o The Cumulative Effects Section of the EIR/EIS should include analyses that show the 
effects of the preferred alternative when operated in conjunction with other future 
SWP facilities. Future SWP facilities should include south Delta facilities, Los Banos 
Grandes Reservoir and the Kern Water Bank. The cumulative impact analysis should 
include evaluation of the effect of the proposed project in combination with these 
SWP facilities that will be competing for the same surplus and high quality water. 

5-196 



Impacts on State Water Project Not Adequately Addressed 

The SWC is concerned that the increased diversions from south Delta channels for the Los 
Vaqueros Project could have an adverse effect on State Water Project (SWP) water 
operations; however, such impacts are not presented in the draft EIR/EIS. While the draft 
EIR/EIS presents the change in simulated storage volumes for CVP reservoirs (Shasta, Qair 
Engle, and Folsom) and simulated river flows immediately downstream of those reservoirs, -s-j i t 

no information is given regarding p>otential impacts on SWP operations. 

o The draft EIR/EIS should be expanded to include the evaluation of potential impacts 
on SWP deliveries and operations including Oroville, Clifton Court Forebay, Harvey 
O. Banks Delta Pumping Plant and SWP storage in San Luis Reservoir. The draft 
EIR/EIS should also include evaluation of the potential increase in carriage water 
requirements for both the SWP and CVP. 

It is our understanding that the Delta channels in the vicinity of the proposed Supplemental 
Intake and the SWP's Clifton Court Forebay are at capacity when the SWP is diverting at the 
maximum rate allowed by the existing Corps of Engineers' Section 10 Permit We are 
concerned that the relative proximity of the proposed intake to DWR's proposed South Delta 
facilities and to the existing Clifton Court Forebay could result in channel capacity 
constraints. 33-14 

o The draft EIR/EIS should identify the cumulative impacts associated with operations 
of the existing and an enlarged Clifton Court Forebay in combination with CCWD's 
New Supplemental Intake on Old River. The draft EIR/EIS should also identify the 
measures which CCWD would undertake to mitigate any impacts. 

The SWC is concerned about the Trihalomethane Formation Potential (THMFP) of SWP 

water diverted from the Delta, and any related impact on water freatment cost and human 

health. In the draft EIR/EIS, evaluation of impacts on water quality are based on the 

simulated Delta salinity defined in terms of chloride concentration and electrical conductivity. 

The draft EIR/EIS neglects to identify any changes in the THMFP which may occur as a 33-15 

result of changes in the flow patterns in south Delta channels when the Los Vaqueros Project 

is operated. 

o The EIR/EIS should address water quality impacts relating to changes in the THMFP 
in the Delta. 

Mitigation Should be Clarified 

As an organization which represents water agencies that depend on water diverted from the 
Delta, the SWC is concerned about declines in fishery populations in the Delta. The need to 33-16 
develop adequate solutions to protect the Delta fisheries has been underscored by recent 
restrictions that have been placed on the SWP's operation of the Harvey O. Banks Delta 
Pumping Plant to protect the endangered winter- run chinook salmon. Accordingly, the SWC 
believes that all proposed projects, which would increase diversions from the Delta, must 

5-197 



attempt to minimize significant fishery impacts and include adequate mitigation programs for 
unavoidable impacts. 

o The draft EIR/EIS shows in addition to its existing intake the new supplemental intake 
would be used to meet future increased demands when surplus water is not available. 
The net effect would be that CCWD would divert more water from the Delta during 
all months of the year (see Figure 2-3 of the draft EIR/EIS). The EIR/EIS should 
identify how increases in reverse flows would impact fishery resources and how the 
impacts will be mitigated. 

o The EIR/EIS states that CCWD could appropriately contribute to programs 
considered as mitigation under the No- Action alternative to offset specific impacts to 
striped bass and Delta smelL Mitigation measures for fishery impacts under the No- 
Action alternative consist of programs that CCWD would have no direct discretion to 
carry out The EIR/EIS should identify the process regarding how CCWD will ensure 
that such mitigation is carried out and what mitigation programs will be developed to 
mitigate fishery impacts in the absence of the No-Action mitigation. 

It is the SWC experience that regulatory agencies may not issue the necessary operational 
permits unless there is an agreement to mitigate for existing impacts as well as the impacts 
associated with increased operations. For example, before the Harvey O. Banks Delta 
Pumping Plant may be operated at full capacity, an agreement with DFG to mitigate for 
existing indirect Delta fishery impacts must be executed. 

o The EIR/EIS should recognize that in order to obtain the necessary permits to allow 
CCWD to increase diversions from the Delta, existing impacts should be mitigated. 
Accordingly, it is expected that fish screens will be required at the Rock Slough Intake. 
Because such mitigation will most likely be required, the EIR/EIS should identify such 
measures to minimize the existing impacts. 

The Draft EIR/EIS states that CCWD would contribute to the ongoing fishery mitigation 
programs, such as those developed under the Two-Agency Fish Agreement The SWC is 
encouraged that CCWD is committed to participating in mitigation programs such as the 
Two-Agency Fish Agreement The EIR/EIS suggests contributing to ongoing fishery 
mitigation programs would serve as adequate mitigation. 

o While the Two-Agency Fish Agreement may serve as a model, it was intended to 

specifically mitigate SWP impacts. The SWC believes that it would be inappropriate 
for CCWD to satisfy its mitigation requirements by contributing to this agreement 
The EIR/EIS should specifically describe programs to offset fishery impacts. Such 
programs should include construction of fish screens on the existing Delta diversion 
intake. Further, CCWD should coordinate with the appropriate fish and wildlife 
agencies (i.e. Department of Fish and Game) and engage in negotiations to develop 
its own mitigation agreements for impacts associated with CCWD's existing operations 
in the Delta as well as operations of the proposed project 



5-198 



o It should be recognized that mitigation programs "such as the Two- Agency Fish 

Agreement may be insufficient to mitigate for the impacts to threatened and 
endangered species. This was evident in 1992 when SWP and CVP Delta pumping was 
curtailed. The EIR/EIS should identify what measures will be implemented to avoid 
impacting winter run salmon when conditions such as those experienced in 1992 occur. 

The State Water Contractors appreciates the CCWD's need for the proposed Los Vaqueros 
Project, and are pleased to note the District's recognition that success of that Project is linked 
to successful resolution of Delta fisheries and water qualify problems. The State Water 
Contractors look forward to a closer, more cooperative, effort with the CCWD and Contra 
Costa Counfy in working toward a mutually beneficial solution to Delta problems. 

The State Water Contractors would be pleased to participate in a meeting with policy 
representatives of DWR, USBR and the CCWD to discuss possible joint cooperative efforts 
in the Delta. We appreciate the opportunity to comment on the Draft EIR/EIS. 



Sincerely, 





George R. Baumli 
General Manager 



cc: SWC Member Agencies 
David Kennedy, DWR 
Roger Patterson, USBR 



5-199 



Responses to Comments of the State Water Contractors 



33-1 . The proposed project would not materially Increase CCWD's ability to deliver water from the Delta 
to its sen/ice area. While the proposed project would eliminate the need to make improvements 
to a portion of CCWD's water conveyance system, major restrictions would still exist in the Contra 
Costa Canal system that would limit CCWD's deliveries to approximately existing conditions. 

33-2. Comment noted. CCWD concurs that increased offstream storage can provide numerous benefits 
and believes that the proposed project achieves these objectives while minimizing environmental 
impacts and impacts on other water users. Analyses conducted for the Stage 2 EIR/EIS did not 
identify any potential impacts on State Water Project operations. 

33-3. CCWD does not believe that its timing and cost objectives preclude the development of a program 
that minimizes environmental impacts. CCWD believes that it is Imperative to proceed with project 
development given the vulnerability of its water supply, which serves over 400,000 people and 
numerous industries, to a major Delta catastrophe. CCWD also considered projects in the Stage 
2 EIR/EIS that substantially exceeded its cost objective and that could not meet its timing 
objective. Through analysis contained in the EIR/EIS, CCWD identified that the proposed project 
would be the least environmentally damaging practicable alternative. 

33-4. As a result of comments received on the draft EIR/EIS and meetings with the various resource 
agencies, CCWD and Reclamation have developed mitigation measures that not only reduce 
Impacts to Delta resources, but actually improve conditions as compared to no project, particularly 
for winter-run chinook salmon. These measures consist of revisions to the proposed project 
operations in terms of the timing and magnitude of diversions from the Delta. Under the proposed 
mitigation plan, CCWD will use a portion of the water stored in the Los Vaqueros Reservoir in lieu 
of direct diversions from the Delta during the winter-run chinook salmon's season of highest 
vulnerability. This operation will allow CCWD to eliminate a!! its diversions from the Delta, including 
those from its existing intake at Rock Slough, for a total of approximately 30 calendar days 
between March 15 and May 15 of each year. In addition, CCWD will generally not fill the Los 
Vaqueros Reservoir between March 15 and May 31. 

The revised project operations are fully described in the biological assessment for the proposed 
project as are the effects of the revised operations on special-status fish species. The mitigated 
operations are also described in Chapter 4 of the final Stage 2 EIR/EIS, along with a discussion 
of effects on other fish species. 

33-5. CCWD recognizes tfiat numerous other programs are being investigated by various agencies. At 
such time as those future projects are approved and receive environmental clearance, CCWD will 
consider coordinating with other appropriate agencies to determine if coordination with those other 
projects could provide significant benefits to the Delta and CCWD. CCWD and DWR have 
coordinated extensively on these and other issues over several years. 

33-6. See respxxise to comment 33-1 above. 

33-7. Surplus water is defined as that quantity of water that is in excess of water needed for consump- 
tive uses or to meet water quality standards and that is available for diversion. Typically, surplus 
flows occur when upstream reservoirs are required to release water to maintain flood control 
storage. 

Figure 5-12 of the biological assessment, provided at the end of responses to comments of the 
State Water Contractors, provides the remaining information requested in this comment. 



Response to Comments of the State Water Contractors 

5-200 



33-8. CCWD has a contract with Reclamation to deliver up to 195,000 acre-feet per year. CCWD will 
continue to rely on this contract to provide most of its water supply, and will divert surplus water, 
subject to certain conditions, to help meet its water quality and emergency supply needs. 
Therefore, diversions to fill the Los Vaqueros Reservoir are unlikely to affect the operation of other 
existing or future projects. See also responses to comments 2-9 and 2-19. 

33-9. See response to comment 33-4, above. In addition, CCWD's proposed operational mitigation 
measures include no filling of the Los Vaqueros Reservoir during May. While the operations do 
allow the filling of the reservoir in June, surplus water of sufficient quality is available in June only 
during very wet years. While CCWD may desire to use previously stored CVP water to fill the Los 
Vaqueros Reservoir during June, Reclamation will retain the ability to decide when CVP water may 
be released for rediversion by CCWD. Also, according to modeling results, water quality is 
typically higher during July and August than June, and CCWD is therefore lil<ely to divert water 
during those months. 

33-10. CCWD's water conservation programs are summarized briefly on page 1 -7 of the Stage 2 EIR/EIS. 
As indicated on page 1-6 of the Stage 2 EIR/EIS, significant additional detail is contained in 
CCWD's Section 404(b)(1) alternatives analysis. 

33-11. The State Water Project demands used in the studies were 3.167 million acre-feet (MAP) 
(representing existing conditions), 3.782 MAP (representing future conditions) and 4.224 MAP 
(representing future cumulative conditions). The years (1990, 2000, and 2025) associated with 
these levels were included as references to the source of the estimates. The current estimates of 
when these demand levels will be reached is neither important nor relevant to the analysis. The 
analyses cover a full range of demand levels for future conditions and therefore cover likely 
impacts regardless of the specific predictions of when these levels will actually be attained. 

As discussed in the Stage 2 EIR/EIS, project deliveries and demands are not the same. While 
demand levels increased about 600,000 af from the existing conditions scenario to the future 
scenario, estimated average deliveries increased by only about 100,000 af. This is because of 
existing physical, hydrdogical, and regulatory constraints. Large increases in demands do not 
necessarily result in large increases in exports. Environmental impacts in the Delta are more 
closely linked to Delta exports than to project demands. 

33-12. As described on page 18-2 of the Stage 2 EIR/EIS, cumulative impacts on Delta water resources 
and fisheries are discussed in the respective technical chapters. The approach to hydrdogic and 
hydrodynamic modeling for cumulative conditions is described on pages 1-10 through 1-12. 
CCWD and Reclamation believe thai the Stage 2 EIR/EIS fully and adequately describes the 
cumulative impacts of the proposed project in conjunction with other future projects. See also 
response to comments 2-9 and 2-19. 

33-13. Tables giving summaries of effects on the State Water Project are included in the Los Vaqueros 
Project files, available for review from CCWD. Information from the model runs is summarized 
below. 

The studies show that the alternatives have a negligible effect on the SWP operations, reservoir 
levels, and deliveries. Deliveries changed in a very snnall number of months. The largest monthly 
decrease In exports (one case of 1 1 ,000 af) was preceded by an increase of a like amount. A net 
reduction of 3,000 af in deliveries over 57 years (50 af/yr average) was calculated in the future 
case; when the accuracy of the model was considered (+/- 5,000 af in any month), this is not 
different than zero. The net deliveries did not change in the existing conditions scenario. 

The project does not cause an increase in carriage water. The project tends to increase CCWD 
diversions when there is surplus flow and to decrease them when the Delta is in balanced 
conditions. The studies showed the largest monthly change in carriage water under existing 
conditions was a decrease of 4,000 af. Of the 10 months with changes, eight involved changes 



flesponse to Comments of the State Water Contractors 

5-201 



of less than 1,000 af (i.e., within the roundoff accuracy and very much smaller than the accuracy 
of the carriage water model). 

Months with increases in carriage water greater than 1 .000 af (1 month under existing conditions, 
4 months under future conditions) were associated with increases in exports at the Banks pump 
plant and/or at the Tracy pump plant. The largest increase was 5,000 af (future conditions). 
Again, this is much smaller than the accuracy of the carriage water model. 

33-14. The proposed new Intake would have a capacity of 250 cfs. The greatest impact would be in the 
vicinity of the intake. If there were no tides, one would exp)ect an increase in velocity on the order 
of 0.3 inches/second. Tidal action reduces any Impacts of this small change because this level 
of pumping would be seen as a slight phase shift and distortion of the tidal flows. (Note that 250 
cfs is about 2.5% of the combined peak SWP and CVP pumping capacity at the Banks and Tracy 
facilities.) Impacts would be correspondingly negligible. 

The effects of a new enlarged forebay cannot be determined unless and until the forebay size, 
location, and operational rules are determined. 

33-15. Trihalomethane formation potential (THMFP) is largely affected by dissolved organic compounds 
and bromide concentration. 

The project would neither affect nor change organic loading in Delta channels. The changed 
inflows caused by the project are too small to cause significant changes in organic concentrations. 
Therefore, this portion of the THMFP problem would not be affected by the proposed alternatives. 

Bromide concentrations will change in proportion to chloride levels (1 mg/l chloride translates to 
about 0.003 mg/l bromide). Most increases in chloride levels identified in the EIR/EIS result from 
increased exports by the SWP and from operational changes necessary to meet increased SWP 
demands. These nnay result in significant increases in THMFP and may have adverse impacts on 
municipal water supplies. 

The chloride increases associated with the preferred alternative would be small, infrequent, and 
are not significant. Consequently, any bromide increases related to the preferred alternative are 
expected to t>e small, infrequent, and not significant. 

33-16. See response to comment 33-1. The mitigation measures described under the No-Action 
Alternative are not proposed to be implemented by CCWD. As described on page 4-51 of the 
Stage 2 EIR/EIS, these mitigation measures are described solely in accordance with NEPA and 
CEQA, to provide a dear distinction between those impacts and related mitigation measures that 
result from changes in background conditions as compared to those impacts that are a direct 
result of implementing the project alternatives. 

33-17. The biological assessment for fish species for the Los Vaqueros Project fully addresses the 
existing losses of fish at CCWD's Rock Slough intake. There are two important points regarding 
the Rock Slough intake. First, the Los Vaqueros Project would, through its normal operations, 
reduce diversions through Rock Slough by 50-80% and instead divert that water through a 
screened intake on Old River where fish can be more efficiently screened. 

Second, only a very small portion of losses associated with CCWD diversions are attributable to 
entrainment. By far the greatest proportion of losses, although still very minor compared to Delta- 
wide losses, result from changes in Delta flow pattems that are negligibly influenced by CCWD 
diversions. Also, a substantial proportion of impacts affect fish species and life stages that are too 
small to be screened, such as larval Delta smelt and striped bass. 

33-18. See response to comment 33-4. 



Response to Comments of ttie State Water Contractors 

5-202 



Existing Conditions 



c 
o 



> 

5 
o 

a 
u 




Old River Intake 



Future Conditions 



u. 

< 



c 
o 



0) 

> 



u 
u 




OCT I DEC I FEB I APR I JUN I AUG 

NOV JAN MAR MAY JUL SEP 



Rock Slough Intake 



wmm Old River Intake 



Figure 5-12. Average CCWD Diversion at Rock Slough and Old River Intakes 



5-203 



Comments of David Mata 



PHl-1 Much of the agricultural runoff that enters the San Joaquin River contains selenium that, in 

high concentrations, has been shown to adversely affect life forms. How does CCWD plan 
to keep selenium out of the reservoir? 

PHI -2 Access to the reservoir recreation facilities appears to be only from the south. Are Alameda 

Ckiunty residents funding the project? 

PHI -3 The draft Stage 2 EIR/EIS states that CCWD now has between 3 and 7 days of emergency 

storage. How many additional days of emergency storage would the Los Vaqueros Reservoir 
provide? 

PHI -4 Why isn't desalination being given more consideration? Desalination could provide water for 

California's future growth and we could implement desalination now. 

PHI -5 CCWD has not looked at relocating Vasco Road but is relying on construction of a proposed 

toll road that would connect Suisun and Sunol. What would be the long-term costs? If a toll 
road is constructed, property values in this area would fall. 



Comments of David Mata 

5-204 



Response to Public Hearing Comments of David Mata 



PH1-1 Selenium occurs naturally in Central Valley soils and is leached into the San Joaquin River 

largely through agricultural irrigation practices. Although selenium levels in the Delta are very 
low t>ecause the flows in the San Joaquin River are higher during winter and therefore the 
dilution factor is greater, levels of selenium in the river are lower. Because the Los Vaqueros 
Project would involve diverting less water during low-flow periods and a greater p)ercentage 
of water supplies during higher flow periods, the overall level of selenium in CCWD supplies 
would be lower, assuming that future levels of selenium in the San Joaquin River do not 
increase. 

In addition, CCWD would regularly release water from the resen/oir to maintain a water quality 
goal for the reservoir of 65 mg/l chloride and 50 mg/l sodium. Selenium would also be 
reduced in proportion to these water quality parameters. 

CCWD water supplies now diverted at Rock Slough do not contain enough selenium to pose 
a significant health risk, and Los Vaqueros would further lower selenium levels. 

PHI -2 The conceptual recreation plan places substantial emphasis on access from the north to 

facilitate use by CCWD ratepayers and other Contra Costa County residents. User fees will 
likely be required from all recreation users, although these fees probably will not completely 
offset the costs of implementing and managing the recreation facilities. 

PHI -3 The Los Vaqueros Reservoir would provide CCWD with between 30 and 90 days of 

emergency storage, depending on the water year type. The specific criteria are described 
on page 1 -5. 

PHI -4 As part of its 404 alternatives analysis required by the Section 404 of the Clean Water Act, 

CCWD conducted a three-stage screening process that evaluated the advantages and 
disadvantages of a comprehensive list of alternatives, including desalination. This EIR/EIS 
constitutes the third stage of the screening process. 

CCWD has not selected desalination as a preferred alternative for several reasons, including 
the following: 

■ Desalination in itself does not provkje emergency water supplies and would not achieve 
CCWD's reliability objectives. CCWD has combined desalination with an emergency 
supply that could be obtained from EBMUD for analysis in the EIR/EIS. The reliability 
and amount of water available from EBMUD in the long-term, however, does not meet 
CCWD's project objectives. 

■ Because of the large amount of electrical energy required for the reverse osmosis 
process, the annual operating costs for the desalination plant would be over four times 
higher than the proposed action as described in Table 2-4a on page 2-45 of the EIR/EIS. 

PHI -5 Vasco Road and utility relocations are a major component of the Los Vaqueros Project. 

CCWD has completed the Vasco Road and Utility Relocation Project EIR as part of the staged 
environmental documentation for the project and is now in the roadway design process. 
CCWD has not attempted to coordinate activities with the California Toll Road Company. 



ResfXinse to Public H«aring Comments of David Mata 

5-205 



Comments of Tim Donohue - Sierra Club 



PH2-1 The draft EIR/EIS does not include conservation as a project alternative nor did other alterna- 

tives Include conservation techniques. Because most of us live with various conservation 
techniques, I would have liked to see these issues addressed. Such conservation measures 
include timers for landscape irrigation, low-flow toilets, and hot water recirculating pumps. 

PH2-2 I did not see access to Vasco Caves discussed in the draft EIR/EIS. In view of the fragile 

nature of the area, access should be limited to organized groups and not the general public. 
The presence of the fairy shrimp near the caves also contributes to the site's sensitivity. 

PH2-3 I did not see addressed in the draft EIR/EIS various cultural resources that are believed to 

have served as Native American gathering sites. Specifically, I did not see discussed an area 
that included a large number of Indian mortars. CCWD should preserve this site and should 
relocate these resources if they are within the inundation zone of the reservoir. 

PH2-4 CCWD has incorporated mitigation for impacts on wetlands. I would like to see CCWD 

design the reservoir shoreline as wetland habitat. 

PH2-5 The loss of oak trees is a concern. To ensure sun/ival of the trees, a minimum of 15-gallon 

trees should be planted in fall. Livestock grazing in the planting area should be banned 
because this would result in the destruction of the small trees. 

PH2-6 We are concerned that grazing will affect water quality in the reservoir and contribute to the 

destruction of the natural habitat. Grazing should be restricted so that water quality is not 
adversely affected, attempts to reforest are not hindered, and the natural cycle of oak and 
other plants is not disrupted. 

PH2-7 Although several other local reservoirs allow swimming, saiitxjarding, and other activities that 

involve body contact with the water, it is not clear whether CCWD would allow such activities 
at the Los Vaqueros Reservoir. Some discussion has also taken place regarding a swimming 
facility that would be separate from the main body of the reservoir. Other than for those who 
are boat owners, access to the Delta is limited. Putdic sentiment seems very supportive of 
resen/oir recreation activities that involve body contact with the reservoir. 



Comments of Tim Donohue - Siena Club 

5-206 



Response to Public Hearing Comments of Tim Donoliue 



PH2-1 CCWD fully evaluated conservation Pleasures as part of its 404(b)(1) alternatives analysis 

required by the Clean Water Act. 

Water conservation does not meet CCWD's water quality or reliability criteria when considered 
as a single alternative. CCWD has Incorporated water conservation in the planning 
assumptions and projected water demands developed to identify CCWD's future water needs. 
Consequently, any alternative or combination of alternatives that is used to meet CCWD's 
basic project purposes will inherently incorporate conservation as a component of the overall 
alternative. 

PH2-2 CCWD does not own or control the Vasco Caves area and therefore does not regulate public 

access. 

CCWD will incorporate measures Into the Ij>s Vaqueros Project that reduce thie potential 
impacts of increased access to the Vasco Caves area to less-than-signlficant levels as 
described in the Vasco Road and Utility Relocation Project EIR and the Stage 2 EIR/EIS. 
CCWD and EBRPD have entered into an agreement to acquire certain lands in the Vasco 
Caves area and to develop an operating agreenrtent to preserve the Vasco Caves resources. 

PI-12-3 The referenced site is above the inundation area. This area has been identified in the 

conceptual recreation plan as a controlled use area (i.e., an area where low-intensity uses that 
do not Involve the loss of the resource could be allowed). Use of this area would be strictly 
controlled by use of signs and gates; monitoring and other controls will be employed to deter 
ir^ppropriate use. 

PH2-4 To obtain a permit from the U.S. Anny Corps of Engineers pursuant to Section 404 of the 

Clean Water Act, CCWD must mitigate for the impacts on wetlands. This mitigation includes 
a variety of replacement strategies that will need to meet with U.S. Army Corps of Engineers 
approval. CCWD has studied the potential for wetland development at the reservoir fringe to 
mitigate wetland losses. The fluctuating reservoir level, however, would inhibit the natural 
development of wetlands. 

PI-12-5 CCWD has committed to an oal< mitigation plan that requires monitoring and remedial action 

should the mitigation fall short of the mitigatton objectives. Although oal< seedlings will be 
used for the initial plantings, irrigation and grazing management would be employed to 
optimize seedlings' chances for survival. 

PI-12-6 CCWD completed a study in 1991 entitled Grazing Intensity and Ground Squin-el Abundance 

In Annu£U Grasslands within the Kellogg Creek Watershed, Contra Costa County, California. 
This study showed tfiat lands within thte watershed that are In private ownership are generally 
overgrazed. Under CCWD ownership, grazing activities would be reduced to avoid water 
quality problems and to genereiliy improve habitat conditions in the watershed. CCWD does 
not desire to severely reduce or eliminate grazing because this would result in unacceptable 
fire risk. 

PH2-7 CCWD recognizes the community Interest In swimming and water-oriented recreation. The 

conceptual recreatkxi plan provides for a swimming lagoon separate from thie main body of 
the reservoir. 



RtSfXinms to Public Hearing Comrmnts o( Tm Donohua 

5-207 



Comments of Tom Butterfiekl 



PH3-1 CCWD should be commended on the job it has done environmentally and othenwise. We 

should move through the planning and environmental process quickly so that we will be 
prepared for future droughts or disasters. 



Comments of Tom Butterfmid 

5-208 



Response to Public Hearing Comments of Tom Butterfield 



PH3-1 Comment noted. 



Response to Public Hearing Comments of Tom Butterfield 

5-209 



Comments of Wesley Van Gilder 



PH4-1 Three years ago, when the citizens of Contra Costa County voted on the ballot measure to 

approve funding for the project, it appeared that there would be two results. Water rates 
would rise substantially and the reservoir would be constructed within 5 years. 

Rates have Increased at the rate approximately one Increase every 6 months, but the 
resen/oir has not been built. Now the reservoir is only tentative, and it appears that rates will 
continue to rise. 



Comments of Wesley Van Gilder 

5-210 



Response to Public Hearing Comments of Wesley V an Gilder 

PH4-1 Comment noted. 



Responses to Public Having Comments of Wesloy Wan Gilder 



5-211 



Comments of Wilhemena Andrade 



PH5-1 The Los Vaqueros Project cannot guarantee that CCWD customers will get tjetter water 

quality, because project operations are based on precipitation and the Sacramento/San 
Joaquin Delta. 

PH5-2 EBMUD has obtained a Sierra water source with the assistance of CCWD and the City of 

Antioch. CCWD customers also deserve such a high-quality water source. CCWD should 
not pursue a project based on the same water source we have now. 

PH5-3 CCWD staff do not regularly attend SWRCB hearings to represent the interests of Its 

ratepayers. SWRCB decisions are largely political. 

PH5-4 The preparers of the draft EIR/EIS have not disclosed the full range of pollutants present in 

the Delta at the time CCWD would divert Los Vaqueros Project water from the Delta. The City 
of Sacramento has and will continue to discharge raw sewage into the Sacramento River 
during winter when project diversion is proposed. I am concerned that this problem has not 
tieen properly addressed. 

PH5-5 The document recommends too much protection for wildlife species and not enough 

protection for CCWD's ratepayers who will pay the high costs of the project. 

PH5-6 The document discusses recreation extensively, however. Contra Costa County voters did not 

vote for a recreational reservoir. 

PH5-7 The document does not adequately discuss the water quality impacts of the intensive seagull 

use of the reservoir that would occur because of the proximity of several landfills. 

PH5-8 The document states on page 16-14 and 17-2, respectively, that CCWD will pay in-lieu fees 

to affected local agencies and will provide water service to east county in the future. This 
is not equitat)le t)ecause east county residents will not pay for the initial cost of construction. 

PH5-9 The document references a CCWD board decision not to include the east county area in the 

planning assumptions for the project. Contra Costa County voters did not give the CCWD 
Board of Directors the discretion to expand the project to include the east county area. 

PH5-10 Without a discussion of the effect on the reservoir of raw sewage from the City of 

Sacramento, the document is inadequate. 

PH5-1 1 The project would also substantially adversely affect salmon. This is ur^cceptat>le because 

salmon are a valuable food source for the people of California. 

PH5-12 The project should not be constructed until the regional water quality control board rescinds 

the City of Sacramento's permit to release untreated wastewater flows during heavy rainfall 
events. 

PH5-13 The document is not adequate until all the mitigation is in place. 



Comments of Wilhemena Andrade 



5-212 



Response to Public Hearing Comments by Wilhemena Andrade 



PH5-1 It is possible that drought situations could delay initial filling of the reservoir and periodically 

prohibit CCWD from maintaining the reservoir at optimal levels. However, the Los Vaqueros 
Project has been designed to meet CCWD's water quality goals during such situations and 
CCWD has completed extensive modeling using existing hydrologic data for a 57-year period. 
The results of these studies have been used to determine the feasibility and design of the 
operations of the project. 

PH5-2 As part of its 404 alternatives analysis required by the Section 404 of the Clean Water Act, 

CCWD conducted a three-stage screening process that evaluated the advantages and 
disadvantages of a comprehensive list of alternatives, including a Sierra water source. 

CCWD found that developing a Sierra source would be unfeasible for the following reasons: 

■ The cost of developing a Sierra source would be considerably higher than the cost 
recommendations stipulated in the voter-approved measure authorizing funding for the 
project. 

■ Water rights that would permit such a project are unavailable. 

■ The project would have prohibitive environmental constraints and obtaining permits 
would probably be unfeasible. 

■ The project would require a long pipeline that would be subject to failure during a major 
earthquake and terminal storage. The terminal storage component alone could have 
environmental consequences similar to those of the entire Los Vaqueros Project. 

Delta water quality problems are periodic. By avoiding these problem periods, CCWD would 
improve the overall quality of its water supplies. 

PH5-3 CCWD closely follows the activities of the California State Water Resources Control Board 

regarding Delta issues and actively represents the interests of its customers on pertinent 
issues. 

PH5-4 Because of the location of CCWD's Rock Slough intake, the flow pattems of the Delta and 

the great dilution factor of the Sacramento River and the Delta during such rainfall events, 
changes in water quality at the CCWD intake after such a sewage release would be 
undetectable. 

PI-15-5 CCWD believes that the mitigation measures incorporated into the project are appropriate and 

consistent with state and federal laws and CCWD board resolutions. 

PH5-6 Recreation was one of the project components identified in measure W that was approved 

by voters within CCWD in 1988. Because, in part, of issues regarding project cost, CCWD 
has proposed a limited amount of recreation development. Costs of future recreation 
development would likely be bome by other funding sources. 

PH5-7 A full discussion of the effects of roosting gulls is Included on page 6-13 of the EIR/EIS. 

Based on the finding and conclusions of a report prepared for CCWD, water quality impair- 
ment of the reservoir from cdiform and pathogen levels will not be a major Issue of concern. 



Responses to Public Hearing Comments by Wilt)emena Ajtdracte 

5-213 



PH5-8 



PH5-9 



CCWD is purchasing the Kellogg Creek watershed, a large land area in east county, and is 
fem^vir^g rt rom the county's L roll thereby potentially reducing furid.ng for sorrie east 
S^unrpuWic service provWes. Recreation uses at the reservoir coud also '"crease the 
S^TkJ for a numt>er of these services. CCWD believes that paying .n-1,eu fees ,s appropn- 
ate^S^ion forTh^se adverse fisc^ ir^pacts. CCWD has no f^ans to provkie Los Vaqueros 
Project benefits to areas outside its existing service area. 

Comment noted. One of the factors resulting in CCWDs decision to not include the east 
counwarea in the planning area for the Los Vaqueros Project was that ratepayers dd not 
have the opportunity to vote on such service. 



PH5-10 See response to PH5-4 

PH5-11 



CCWD concurs that salmon are an important wildlife resource. As mitigation for impacts 
S^ by the pro^sed action, CCWD has modrtied rts project operations to produce a net 
benefit for winter-run chinook salmon. 



PH5-12 See response to PH5-4 

PH5-13 

adopted or constructed. 



See response to PH5-4. 

Except where required as permit conditions or where specified in the mitigation monitoring 
^an'ldera[aS state laws do not require mrtigation to be in ^^ace at the time the pro,ect is 



Responses to Public Hearing Comments by Wilhemena Andrade 

5-214 



Comments of Burt Weinstein • Bicycle Trails Council for the East Bay 



PH6-1 The recreation document prepared for the project does not address mountain bikes. CCWD 

appears to have obtained data for the recreation plan by contacting other local agencies. We 
do not believe that these agencies are an effective source of data for our type of recreational 
activity. Please contact us for data regarding mountain biking. 



Comrmnts of Burt V^insivin ■ Bicycle Trails Council for ttm East Bay 

5-215 



Response to Public Hearing Comments of Burt Weinstein 



PH6-1 CCWD has no plans to restrict nrKMjntain bil<es from trails In the Kellogg Creek watershed, 

although some trails may be restricted at various times to minimize conflicts between various 
user groups, protect sensitive cultural resources, or other operational requirements. 

As CCWD develops more specifte recreation plans for the watershed lands, it will consult with 
the referenced organization on issues regarding bicycling. 



Response to Public Hearing Comments of Burt Weintteir 

5-216 



Comments of Frank Lehmkuhl 



PH7-1 Because of its proximity to tiie Tosco oil refinery, water at the Bollman Water Treatment Plant 

is contaminated. CCWD water supplies have substantially higher levels of water supply 
contaminants than EBMUD water supplies and CCWD will not act to remove them. 

PH7-2 CCWD will be unable to fill the reservoir because the winter snowpack is not of sufficient 

volume. 

PH7-3 The reservoir will not provide water quality laenefits because the reservoir will contain 

unacceptable levels of sodium that CCWD will be unable to remove. 

PH7-4 CCWD should admit that it is continuing to ration water supplies because it is requiring its 

customer to reduce consumption by 15% over last year. 

PH7-5 CCWD did not fully disclose the true cost of purchasing the Kellogg Creek watershed lands. 



Comments of Frank Lehmkuhl 

5-217 



Response to Public Hearing Comments of Frank Lehmkuhl 



PH7-1 CCWD has detected no contamination of its water supply from nearby industries. The Los 

Vaqueros Project will reduce the levels of most water quality contaminants. CCWD's water 
supply is also thoroughly treated and meets all state and federal drinking water standards. 

PH7-2 See response to PH5-1. 

PH7-3 The project has been carefully formulated to maintain a water quality goal at the tap of 65 

mg/l chloride and 50 mg/l sodium. CCWD would maintain this goal by filling the resen/oir 
during periods when Delta water quality is high. Currently, CCWD meets this water quality 
goal only 59% of the time. With the Los Vaqueros Project, this goal could be met approxi- 
mately 90% of the time. 

PH7-4 CCWD has maintained a volunteer rationing program with the intent of achieving a 15% 

reduction in customer use. 

PH7-5 CCWD is required to purchase Kellogg Creek watershed lands at fair market value. In some 

cases, the value of lands has been higher than anticipated by CCWD. 



Response to Public Hearing Comments of Frank Lehmkuhl 

5-218 



5-219 




P00001927